Motion to Modify Conditions of Release — US v. Ponzo

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U.S. District Court, District of New Jersey · No. 1:23-mj-02053-AMD · Doc. 13 · 2023-09-08 · Docket on CourtListener

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21 ROUTE 130 SOUTH  CINNAMINSON, NEW JERSEY 08077 
PHONE (856) 786-7000  ∙  FAX (856) 385-8181 
AFONSO ARCHIE LAW, P.C. 
ATTORNEYS AT LAW 
 
ALBERT M. AFONSO, ESQ. ‡* 
TROY A. ARCHIE, ESQ. 
 
 
 
 
 
ARCHIE@AANJLAW.COM 
KERLIN HYPPOLITE, ESQ. 
ANDRE A. NORWOOD JR., ESQ.  
 
 
 
 
 
 
 
 
 
            
‡ ALSO MEMBER OF PA BAR 
* ALSO MEMBER OF VT BAR 
 
 
September 8, 2023 
 
VIA PACER 
Honorable Ann Marie Donio 
United States Magistrate Judge 
Mitchell H. Cohen Courthouse 
4th And Cooper Streets 
Camden NJ 08101-0000 
 
Re: USA v. Adrienne Ponzo 
        Case No.: 23-mj-2053 (AMD)  
 
Dear Judge Dunio, 
 
As the court is aware, the undersigned was appointed to represent Ms. Ponzo in the above 
referenced matter. On behalf of the defendant, kindly accept this letter as a request for a hearing 
regarding change of conditions of release for the defendant, who is currently under home 
detention – (DOC. 11). Ms. Ponzo is currently supervised by US. Pretrial Services in the Eastern 
District of Pennsylvania as she is a Pennsylvania resident.  
 
Ms. Ponzo is permitted to work and currently has a job with Sloan Monroe Logistics, 
supervised by Samantha Hollis (302) 298 – 5891. Her employment information is attached here 
to as Exhibit “A”. Ms. Ponzo has a commercial driving license, (CDL), and Sloan Monroe 
Logistics has additional duties for her including driving loads to different states.  
 
Because Ms. Ponzo has two special needs children she really needs the income to keep 
her family afloat. She is seeking modification of her conditions of release to be allowed to travel 
for work related purposes and will report her work schedule and whereabouts to US Pre-trial 
services as required.  
Case 1:23-mj-02053-AMD     Document 13     Filed 09/08/23     Page 1 of 2 PageID: 49

 
21 ROUTE 130 SOUTH  CINNAMINSON, NEW JERSEY 08077 
PHONE (856) 786-7000  ∙  FAX (856) 385-8181 
 
The Government opposed her release during her initial appearance (DOC. 11) The 
undersigned argued the defendant was not a flight risk and did not pose a threat to the 
community, and pursuant to IB U.S.C (§) 3142 (c) there were reasonable measures to ensure the 
defendant would not flee and endanger the safety of any persons of the community. The Court 
agreed. Ms. Ponzo has abided by those conditions and seeks only this modification for work 
related purposes.  
 
I have reached out to the Government and U.S. Pre-Trial seeking consent but have not 
heard back regarding a consent or objection. This Motion follows.  
 
The defendant respectfully requests a hearing on this matter as soon as the court is 
available.  
 
Thank you for your attention and courtesies in this matter.  
 
 
 
 
 
 
 
 
 
 
Respectfully submitted,  
 
 
 
 
 
 
 
 
 
/s/ Troy A. Archie, Esq.  
 
 
cc:  
Daniel A. Friedman, AUSA  
  
Acheme Amali, US Pre-Trial NJ  
Charles Meissler, US Pre-Trial EDPA  
 
 
Case 1:23-mj-02053-AMD     Document 13     Filed 09/08/23     Page 2 of 2 PageID: 50

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