Motion - United States v. Maurice Fayne related docket (Doc. 66, filed 2020-08-21)

Summary

Document 66, filed 08/21/20 in No. 1:20-CR-228-MHC-JKL in the U.S. District Court for the Northern District of Georgia, Atlanta Division, is a four-page unopposed motion to modify conditions of release by defendant Daniel Eric Jay, with a proposed order, signed by attorney Kamal Ghali. Jay lives in the Western District of Pennsylvania under bond conditions limiting his travel. He asks to travel from Sunday August 23rd to Wednesday August 26th with his ill father to York, Pennsylvania and the Washington D.C. area to visit family. The motion says Probation Officer Matthew Anderson and Assistant U.S. Attorney Russell Phillips do not oppose. The attached order, dated August 21, 2020 over the name Russell G. Vineyard, U.S. Magistrate Judge, grants the modification for those dates.

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IN THE UNITED STATES DISTRICT COURT 
FOR THE NORTHERN DISTRICT OF GEORGIA 
ATLANTA DIVISION 
 
UNITED STATES OF AMERICA
v. 
DANIEL ERIC JAY 
Criminal Action No. 
1:20-CR-228-MHC-JKL 
 
DEFENDANT JAY’S UNOPPOSED MOTION TO  
MODIFY CONDITIONS OF RELEASE  
Defendant Daniel Eric Jay respectfully requests that this Court modify his 
conditions of release to permit him to travel outside the Western District of 
Pennsylvania from Sunday August 23rd to Wednesday August 26th.   
Mr. Jay is charged in the above referenced case number ending in the 
Northern District of Georgia. But he lives in the Western District of Pennsylvania 
under bond conditions that restrict his travel outside WDPA. Doc. 4.   
Mr. Jay requests permission to travel outside of WDPA with his father to visit 
family. Mr. Jay’s father is ill, and Mr. Jay requests permission to travel with his 
father to York, Pennsylvania and to the Washington D.C. area.  
Undersigned counsel has spoken with U.S. Probation Officer Matthew 
Anderson (who is Jay’s Probation Officer) and Assistant U.S. Attorney Russell 
Phillips. Neither the U.S. Attorney’s Office for the Northern District of Georgia 
nor the U.S. Probation Office opposes this request. A proposed order is attached. 
 
Respectfully submitted this 21st day of August, 2020. 
 
/s/ Kamal Ghali 
 
 
 
Kamal Ghali 
Georgia Bar No. 805055 
ghali@bmelaw.com 
 
Case 1:20-cr-00228-MHC-JKL     Document 66     Filed 08/21/20     Page 1 of 4

2 
 
BONDURANT, MIXSON & ELMORE, LLP 
1201 West Peachtree Street, N.W., Suite 3900 
Atlanta, Georgia  30309 
(404) 881-4100 – Telephone 
(404) 881-4111 – Facsimile 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Case 1:20-cr-00228-MHC-JKL     Document 66     Filed 08/21/20     Page 2 of 4

1 
 
IN THE UNITED STATES DISTRICT COURT 
FOR THE NORTHERN DISTRICT OF GEORGIA 
ATLANTA DIVISION 
 
UNITED STATES OF AMERICA
v. 
DANIEL ERIC JAY 
Criminal Action No. 
1:20-CR-228-MHC-JKL 
 
ORDER MODIFYING CONDITIONS OF RELEASE 
Defendant Daniel Eric Jay requests that this Court modify his conditions of 
release to permit him to travel outside the Western District of Pennsylvania from 
Sunday August 23rd to Wednesday August 26th.   
Given the absence of any opposition from the Government and the U.S. 
Probation Office, Jay’s conditions of release are HEREBY MODIFIED to permit 
him to travel outside the Western District of Pennsylvania to York, Pennsylvania 
and the Washington D.C. area from Sunday August 23rd to Wednesday August 
26th 
SO ORDERED this 21st day of August, 2020. 
 
________________________ 
 
RUSSELL G. VINEYARD 
 
 
 
 
 
U.S. MAGISTRATE JUDGE 
 
 
 
 
 
Case 1:20-cr-00228-MHC-JKL     Document 66     Filed 08/21/20     Page 3 of 4

3 
 
CERTIFICATE OF SERVICE 
 
I hereby certify that this 21st day of August, 2020, a copy of the foregoing 
UNOPPOSED MOTION TO MODIFY CONDITIONS OF RELEASE was 
electronically filed with the Clerk of the Court and copies sent to all counsel of 
record via the ECMF system. 
 
/s/ Kamal Ghali 
 
 
Kamal Ghali 
Georgia Bar No. 805055 
ghali@bmelaw.com 
 
Case 1:20-cr-00228-MHC-JKL     Document 66     Filed 08/21/20     Page 4 of 4

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