Motion by Te Dora Brown to modify conditions of release — USA v. Brown, et al. (Dkt. 29, N.D. Ill.)

Record facts

U.S. District Court for the Northern District of Illinois · No. 1:23-cr-00097 · Doc. 29 · 2023-04-11 · Docket on CourtListener

Full text

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
UNITED STATES OF AMERICA,
)
)
Plaintiff, 
)
)
v.
)
No.  23 CR 97
)
)
Judge Elaine E. Bucklo
)
TE DORA BROWN,
)
)
Defendant.
)
UNOPPOSED MOTION FOR TRAVEL AND TO
MODIFY CONDITIONS OF RELEASE
Defendant, Te Dora Brown, by and through her attorney, Victor P. Henderson, 
respectfully requests that this Court approve travel relating to business as described 
below and to modify the conditions of her release to allow subsequent travel to be 
approved by pre-trial and without the need to seek leave of Court.  In support thereof, 
Ms. Brown states as follows:
1.
Ms. Brown was charged with wire fraud (Docket No. 1).
2.
Ms. Brown pleaded not guilty on March 1, 2023 (Docket No. 9).
3.
The conditions of Ms. Brown’s release restrict her travel to within the 
Northern District of Illinois (Docket No. 13).
4.
Ms. Brown earns her living, in part, by engaging in entrepreneurial 
presentations, which require her to travel.
5.
She has three upcoming trips in 2023.  To wit:
Case: 1:23-cr-00097 Document #: 29 Filed: 04/11/23 Page 1 of 4 PageID #:117

2
Place
Dates
Jackson, MS
April 18 – April 20
Bronx, NY
April 29 – April 30
Houston, TX
May 11 – May 14
6.
She would like approval to take these trips.
7.
In addition, Ms. Brown would like to modify the conditions of her release 
so that she can travel within the continental United States without seeking leave of 
Court.  Instead, she would only need to obtain the approval of her pre-trial officer, 
John Riehl
8.
On or around April 10, 2023, counsel for Ms. Brown, Victor P. 
Henderson, communicated with pre-trial services officer, John Riehl.  He does not 
oppose this motion.
9.
On or around April 10, 2023, counsel for Ms. Brown, Victor P. 
Henderson, communicated with AUSA Alejandro G. Ortega, who also informed 
counsel that he does not oppose this motion. 
Case: 1:23-cr-00097 Document #: 29 Filed: 04/11/23 Page 2 of 4 PageID #:118

3
WHEREFORE, Ms. Brown respectfully requests that her conditions of release 
be modified so that she can travel within the continental United States without 
needing to seek permission from the Court, provided that pretrial has approved her 
travel, and she also seeks approval of the three trips listed above and for such other 
and further relief as this Court deems just.
DATED:
April 11, 2023
Respectfully submitted,
By:
/s/ Victor Henderson
Attorney for Te Dora Brown
Victor P. Henderson
HENDERSON PARKS, LLC
140 South Dearborn, Suite 1020
Chicago, IL 60603
Phone: (312) 262-2900
Facsimile: (312) 262-2901
vphenderson@henderson-parks.com
Case: 1:23-cr-00097 Document #: 29 Filed: 04/11/23 Page 3 of 4 PageID #:119

4
CERTIFICATE OF SERVICE
I hereby certify that on April 11, 2023, I electronically filed Defendant’s 
UNOPPOSED MOTION FOR TRAVEL AND TO MODIFY CONDITIONS OF 
RELEASE with the Clerk of the Court using the CM/ECF system which will send 
notification of such filing to all counsel of record.
/s/ Victor P. Henderson
Case: 1:23-cr-00097 Document #: 29 Filed: 04/11/23 Page 4 of 4 PageID #:120

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