Motion to Modify Conditions of Release as to Erin Jare Brown — USA v. Adiana Pierre, et al. (Brown) (Dkt. 22, D. Mass.)

Summary

An unopposed Motion to Modify Conditions of Release, filed April 14, 2023 as Document 22 by Defendant Erin Brown Ford in the U.S. District Court for the District of Massachusetts, Case No. 23-mj-5013-JGD-2. The motion asks the court to modify a condition of pretrial release so that Mrs. Ford may obtain an increase in a credit card limit and apply for a new cell phone plan that will require a credit check. It states that the release condition bars any loan applications absent prior approval from the probation officer, and that probation directed Mrs. Ford to seek court approval. It states that counsel for the government does not oppose the motion. It is signed /s/ Joan M. Griffin.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Record facts

Full text

UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS
____________________________________
 )
UNITED STATES OF AMERICA
 )
 )
Plaintiff,
 ) 
 )
v.
 )
Case No. 23-mj-5013-JGD-2
 )
ERIN BROWN FORD,
 )
 )
Defendant.
 )
____________________________________)
DEFENDANT ERIN BROWN FORD'S 
UNOPPOSED M
 
 OTION TO MODIFY CONDITIONS OF RELEASE
Defendant Erin Brown Ford respectfully requests that the Court modify a condition of her
pretrial release and allow her to obtain an increase in her credit card limit and to apply for a new 
cell phone plan which will require a credit check.
In support of this motion, Mrs. Ford states as follows:
1. Mrs. Ford and her husband Wallace Ford were both arrested and charged in this matter. 
Mrs. Ford was subsequently released on conditions, including a condition requiring that 
Mrs. Ford “not submit any loan applications absent prior approval from the probation 
officer.”
2. Pursuant to the relevant release condition, undersigned counsel asked probation to 
approve Mrs. Ford’s increase in her credit card limit and application for a new cell phone 
plan, but probation has demurred and directed that Mrs. Ford seek Court approval.
3. Since her release, Mrs. Ford has been a model supervisee and has complied with all 
release conditions. The increase in her credit card limit and new cell phone plan are 
Case 1:23-mj-05013-JGD     Document 22     Filed 04/14/23     Page 1 of 2

needed to allow the Fords to meet their everyday expenses in the most cost effective way 
possible.
4. Undersigned counsel has conferred with counsel for the government in this matter, and he
does not oppose this motion.
WHEREFORE, Mrs. Ford respectfully requests that this Court ALLOW this motion and
modify the conditions of her release to allow her to obtain an increase in her credit card limit and
to apply for a new cell phone plan which will require a credit check.
Respectfully Submitted,
ERIN BROWN FORD
By her attorney,
      /s/ Joan M. Griffin        
Joan M. Griffin (BBO# 549522)
PO Box 133
Dublin, NH 03444 
Griffin@LawJMG.com, (617) 283-0954
April 14, 2023
CERTIFICATE OF SERVICE
 I hereby certify that the above document was served on all parties of record by ECF 
filing on April 14, 2023.
/s/ Joan M. Griffin
Joan M. Griffin
2
Case 1:23-mj-05013-JGD     Document 22     Filed 04/14/23     Page 2 of 2

File and source

File

gov.uscourts.mad.252839.22.0.pdf

Size

82,624 bytes

SHA-256

08d5caf1e8f42066cc4ea833a47c8cac68d168abfffa08d3634a93d259edb01c

Our copy

gov.uscourts.mad.252839.22.0.pdf

Original

PACER (login required)