Court filing

Motion to Modify Conditions of Release — US v. Ponzo

Summary

Document 13, filed 09/08/23 in Case 1:23-mj-02053-AMD, is a letter dated September 8, 2023 from Troy A. Archie, Esq. of Afonso Archie Law, P.C. to the Honorable Ann Marie Donio, United States Magistrate Judge, regarding USA v. Adrienne Ponzo, District of New Jersey. It requests a hearing on a change of conditions of release for the defendant, who is currently under home detention, so that Ms. Ponzo may travel for work related purposes, stating that Ms. Ponzo has a commercial driving license and a job with Sloan Monroe Logistics. It states that the Government opposed release at the initial appearance and that counsel has not heard back from the Government or U.S. Pre-Trial about consent. It is signed /s/ Troy A. Archie, Esq.

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Filed September 8, 2023 in U.S. v. Adrienne Ponzo; one of 163 filings from this case.

Record facts

Court	U.S. District Court, District of New Jersey
Filed	2023-09-08

Cite this document

“Motion to Modify Conditions of Release — US v. Ponzo.” U.S. District Court, District of New Jersey, No. 1:23-mj-02053-AMD, Doc. 13, filed 2023-09-08. Archived at Pandemic Darlings, https://pandemicdarlings.com/court-filings/us-v-adrienne-ponzo-njd/2023-09-08-motion-modify-conditions-of-release-dkt-13/, SHA-256 dae285cd027211f17d01a024a030b7e9dda465d3c84606c0cf027a5f98dfcedc.

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Full text

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

File and source

File: gov.uscourts.njd.514825.13.0.pdf
Size: 405,276 bytes
SHA-256: dae285cd027211f17d01a024a030b7e9dda465d3c84606c0cf027a5f98dfcedc
Our copy: gov.uscourts.njd.514825.13.0.pdf
Original: PACER (login required)