Motion - United States v. Maurice Fayne related docket (Doc. 203, filed 2021-06-29)

Summary

An Unopposed Motion to Modify Conditions of Bond filed June 29, 2021, as Document 203 in United States v. Daniel Eric Jay, No. 1:20-CR-228-2 (MHC) (JKL), in the U.S. District Court for the Northern District of Georgia. The motion, signed by L. Burton Finlayson as attorney for Daniel Jay, petitions under 18 U.S.C. Section 3145 (a)(2) to amend travel restrictions to allow travel into the adjacent Northern District of Ohio. It states that on July 15, 2020, Daniel Jay came before the Honorable Maureen P. Kelly in the Western District of Pennsylvania and was granted a bond with conditions. It states that the U.S. Probation Officer has no objection and that AUSA Russell Phillips defers to the Probation Officer and does not object.

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IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION
UNITED STATES OF AMERICA
)
)
)
v.
)     1:20-CR-228-2 (MHC) (JKL)
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)
DANIEL ERIC JAY
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____________________________
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UNOPPOSED MOTION TO MODIFY CONDITIONS OF BOND
COMES NOW DANIEL ERIC JAY, by and through the undersigned 
attorney, pursuant to 18 U.S.C. Section 3145 (a)(2), and respectfully petitions this 
Honorable Court to modify the conditions of his release while he is awaiting trial 
on the above-styled case.  Specifically, Mr. Jay asks that his travel restrictions be 
amended to allow him to travel into the adjacent Northern District of Ohio.  In 
support of this motion DANIEL JAY shows as follows:
1.
On July 15, 2020, DANIEL JAY came before the Honorable Maureen P. 
Kelly in the Western District of Pennsylvania and was GRANTED a bond with 
conditions which included travel restrictions to the Western District of 
Pennsylvania and the Northern District of Georgia (for court appearances).  (Doc.
Case 1:20-cr-00228-MHC-JKL     Document 203     Filed 06/29/21     Page 1 of 4

4-7, p.2).  Mr. Jay made his initial appearance in this district by video before 
Judge Baverman on July 20, 2020.  (Doc. 6).   Mr. Jay has been home in the 
Western District of Pennsylvania on said bond since July 15, 2020. 
2.
In or about September of 2020, Mr. Jay moved back in with his ailing father 
in BESSEMER, PA, and became his care-giver.  In June of 2021, Mr. Jay’s father 
had a foot amputated.  He is scheduled to move to a medical rehabilitation facility 
soon.  BESSEMER, PA, is located on the boarder of the Western District of 
Pennsylvania and the Northern District of Ohio.  Mr. Jay’s father is scheduled to 
move to a medial rehabilitation facility located in the Northern District of Ohio.  
Furthermore, the closest shopping centers for purchasing food, home and medical 
supplies are located just across the border from Bessemer, PA, in Northern Ohio, as 
are most doctors' offices and facilities. 
3.
Thus, Mr. Jay asks to be allowed to travel into the Northern District of 
Ohio, as well as the Western District of Pennsylvania. 
4.
Undersigned counsel has spoken with Mr. Jay’s U.S. Probation Officer, 
PETER GAWLINSKI, in the Western District of Pennsylvania.  He does not
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Case 1:20-cr-00228-MHC-JKL     Document 203     Filed 06/29/21     Page 2 of 4

oppose Mr. Jay’s request and believes it makes logistical sense in light of where
Mr. Jay resides (right on the border).  The Probation Officer has no objection to
Mr. Jay having his conditions modified in the manner sought.
5.
AUSA RUSSELL PHILLIPS defers to the Probation Officer and does not
object to this request.
WHEREBY, DANIEL JAY requests that this Honorable Court modify  his
conditions of bond to allow him to travel also into the adjoining Northern District
of Ohio.
Dated:  This 29th day of June, 2021.
Respectfully submitted,
 
s/ L. Burton Finlayson 
L. BURTON FINLAYSON
Attorney For DANIEL JAY
Georgia Bar Number: 261460
LAW OFFICES OF
L. BURTON FINLAYSON, LLC 
931 Ponce de Leon Avenue, NE
Atlanta, Georgia 30306
(404) 872-0560
lbfcourts@aol.com
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Case 1:20-cr-00228-MHC-JKL     Document 203     Filed 06/29/21     Page 3 of 4

CERTIFICATE OF SERVICE
This is to certify that I have this day electronically filed the foregoing
Motion to Modify Bond with the Clerk of Court using the CM/ECF system which
will automatically send email notifications of such filing to all counsel of record
including the following:
     Mr. Russell Phillips . 
     Assistant United States Attorney
     600 U.S. Courthouse
     75 Ted Turner Drive, S. W.
     Atlanta, Georgia  30303
DATED:  This 29th day of June, 2021.
 s/ L. Burton Finlayson 
L. BURTON FINLAYSON
ATTORNEY FOR DANIEL JAY   
   
State Bar Number: 261460   
  
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Case 1:20-cr-00228-MHC-JKL     Document 203     Filed 06/29/21     Page 4 of 4

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