Motion - United States v. Maurice Fayne related docket (Doc. 71, filed 2020-08-25)

Summary

Defendant Jay's Second Unopposed Motion to Modify Conditions of Release, Document 71, filed 08/25/20 in United States v. Daniel Eric Jay, No. 1:20-CR-228-MHC-JKL (N.D. Ga.), listed on the Fayne related docket. Jay, who lives in the Western District of Pennsylvania under travel limits, asks to travel with his ill father to York, Pennsylvania and the Washington D.C. area until Saturday, August 29, 2020, because he had not yet left after an earlier approved window. His counsel Kamal Ghali says neither the U.S. Attorney's Office nor Probation opposes. An attached order signed by Magistrate Judge Russell G. Vineyard on August 25, 2020 grants the change.

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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 SECOND 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 until Saturday August 29, 2020. 
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.  
This Court previously authorized Mr. Jay to travel from Sunday August 
23rd to Wednesday August 26th.  But as of August 25, 2020, he has not yet left the 
WDPA and he respectfully requests that he be authorized to travel until 
Saturday August 29, 2020.  Extending his time to travel until Saturday August 29, 
2020 would give him a similar amount of time to visit family with his father. 
Undersigned counsel has spoken with U.S. Probation Officer Matthew 
Anderson (who is Jay’s Probation Officer) and Assistant U.S. Attorney Russell 
Case 1:20-cr-00228-MHC-JKL     Document 71     Filed 08/25/20     Page 1 of 4

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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 25th day of August, 2020. 
 
/s/ Kamal Ghali 
 
 
 
Kamal Ghali 
Georgia Bar No. 805055 
ghali@bmelaw.com 
 
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 71     Filed 08/25/20     Page 2 of 4

 
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 
August 25, 2020 until Saturday August 29, 2020.   
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 August 25, 2020 until Saturday August 29, 
2020.   
SO ORDERED this 25th day of August, 2020. 
 
 
________________________ 
 
RUSSELL G. VINEYARD 
 
 
 
 
 
U.S. MAGISTRATE JUDGE 
 
 
 
 
Case 1:20-cr-00228-MHC-JKL     Document 71     Filed 08/25/20     Page 3 of 4

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CERTIFICATE OF SERVICE 
 
I hereby certify that this 25th 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 71     Filed 08/25/20     Page 4 of 4

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