Assented to Motion to Modify Conditions of Release as to Chynna Savath — USA v. Savath (Dkt. 12, D. Mass.)

Record facts

U.S. District Court for the District of Massachusetts · No. 1:21-cr-10269-RGS · Doc. 12 · 2022-04-28 · Docket on CourtListener

Full text

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UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF MASSACHUSETTS 
 
__________________________________________ 
 
 
 
 
 
 
 
) 
UNITED STATES OF AMERICA,  
 
) 
 
 
 
 
 
 
 
) 
 
v. 
 
 
 
 
 
)   Criminal No.:  1:21-CR-10269 
 
 
 
 
 
 
 
) 
CHYNNA SAVATH,  
 
 
 
) 
 
 
 
Defendant. 
 
 
) 
__________________________________________) 
 
DEFENDANT’S ASSENTED-TO MOTION TO  
MODIFY HER CONDITIONS OF RELEASE 
 
Undersigned counsel for the Defendant Chynna Savath hereby moves this Court for an 
Order allowing her to travel from her current residence in New York to New Jersey for two days 
and one overnight, on April 29-30, 2022.   
In support of this Motion, undersigned counsel states as follows: 
1. On January 20, 2022, Defendant plead guilty to two counts of wire fraud in 
violation of 18 U.S.C. § 1343.  Pursuant to a Rule(c)(1)(C) plea agreement, 
the parties have agreed to a sentencing in this case of 36 months of probation, 
restitution, forfeiture, and the required special assessment.  Defendant’s 
sentencing is currently scheduled for May 19, 2022. 
2. Also on January 20, 2022, this Court released Defendant’s pending sentencing 
on a series of conditions, including a requirement that her travel be limited to 
the states of Massachusetts, Rhode Island, Connecticut and New York.  See 
Docket Entry #11.  Since that date, Defendant has been in compliance with all 
conditions of her release. 
Case 1:21-cr-10269-RGS     Document 12     Filed 04/28/22     Page 1 of 3

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3. Defendant is currently residing in the state of New York, where she is being 
supervised directly by the United States Pretrial Services Office for the 
Southern District of New York. 
4. Defendant’s sister, who resides in Washington State, is planning to visit 
Defendant in New York during the weekend of April 29-May 1, 2022.  The 
two hope to travel together to spend an overnight in Atlantic City, New Jersey 
on April 29-30, 2022. 
5. Defendant has informed her supervising Pretrial Services Officer about her 
proposed travel plans to New Jersey on April 29-30, 2022, and the Pretrial 
Services Office has stated that it does not object to those proposed travel 
plans. 
6. Undersigned counsel has conferred with counsel for the United States 
regarding Defendant’s proposed travel plans to New Jersey.  Counsel for the 
United States does not object to Defendant’s proposed travel plans. 
WHEREFORE, Defendant respectfully requests that this Court issue an Order modifying 
its Conditions of Pretrial Release in order to allow Defendant to travel to the State of New Jersey 
on April 29-30, 2022.   
 
 
 
 
 
 
Respectfully submitted, 
DEFENDANT, CHYNNA SAVATH, 
By her attorney, 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
/s/ Daniel J. Cloherty  
 
 
 
 
 
 
 
 
Daniel J. Cloherty (BBO# 565772) 
 
 
 
 
 
 
Todd & Weld LLP 
 
 
 
 
 
 
One Federal Street 
 
 
 
 
 
 
Boston, MA  02110 
 
 
 
 
 
 
(617) 720-2626 
 
 
 
 
 
 
 
dcloherty@toddweld.com  
Case 1:21-cr-10269-RGS     Document 12     Filed 04/28/22     Page 2 of 3

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CERTIFICATE OF SERVICE 
 
I, the undersigned, hereby certify that I served a true copy of the above document upon 
all parties with an interest in this matter by electronically filing through this Court’s CM/ECF 
filing system this 28th day of April, 2022. 
 
 
 
 
 
 
/s/ Daniel J. Cloherty 
 
 
 
 
 
 
 
 
 
 
Daniel J. Cloherty 
 
 
 
 
 
 
 
 
 
Case 1:21-cr-10269-RGS     Document 12     Filed 04/28/22     Page 3 of 3

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