Motion to Modify — United States v. Reich (Dkt. 19, E.D. Va.)

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A motion to modify conditions of release filed January 22, 2024 by defendant Maria Reich through Assistant Federal Public Defender Kirsten R. Kmet in United States of America v. Maria Reich, Criminal No. 2:23cr135, in the U.S. District Court for the Eastern District of Virginia, Norfolk Division. It asks the Court to suspend payments of $2,000.00 a month. It states that at her November 27, 2023 initial appearance Magistrate Judge Lawrence R. Leonard directed her to reimburse the Government at that rate once the sale of her home was completed (ECF No. 6), that on December 19, 2023 the magistrate judge endorsed a warrant to seize $176,878.53 in net sale proceeds, and that the sale is complete and that amount was seized.

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Case 2:23-cr-00135-EWH-LRL Document 19 Filed 01/22/24 Page 1 of 3 PageID# 57




                       IN THE UNITED STATES DISTRICT COURT
                       FOR THE EASTERN DISTRICT OF VIRGINIA
                                   Norfolk Division


UNITED STATES OF AMERICA

v.                                                  CRIMINAL NO. 2:23cr135

MARIA REICH,

                      Defendant.


                                    MOTION TO MODIFY

       COMES NOW the defendant, Maria Reich, by counsel, and moves this Honorable Court

to modify the conditions of her release to suspend payments in the amount of $2,000.00. In support

thereof, Ms. Reich submits the following:

       1. On November 27, 2023, Ms. Reich made her initial appearance before the Honorable

           Lawrence R. Leonard, United States Court Magistrate Judge, and her conditions of

           release were set. This Honorable Court directed Ms. Reich to “reimburse the

           Government at the rate of $2,000.00 per month once sale of home is completed.”

           “Payments to begin 1/1/24 and continue each month thereafter until paid in full.” ECF

           No. 6.

       2. On December 19, 2023, the Honorable Lawrence R. Leonard endorsed a Warrant to

           Seize Property Subject to Forfeiture for net proceeds from sale of the real property in

           the amount of $176,878.53.

       3. The sale of Ms. Riech’s home has been completed, and the total due to seller was $26,

           987.77. $176,878.53 was seized pursuant to the aforementioned Warrant to Seize

           Property Subject to Forfeiture.

Case 2:23-cr-00135-EWH-LRL Document 19 Filed 01/22/24 Page 2 of 3 PageID# 58




       WHEREFORE, in light of the fact that Ms. Reich did not net the entire proceeds from the

sale of said real property, it is respectfully requested that this Honorable Court modify and suspend

Ms. Reich’s obligation to make a monthly reimbursement to the Government in the amount of

$2,000.00.

                                              Respectfully submitted,

                                              MARIA REICH

                                              By:                 /s/___________
                                                              Of Counsel

                                                      Kirsten R. Kmet
                                                      VSB No.: 47786
                                                      Assistant Federal Public Defender
                                                      Counsel for Maria Reich
                                                      Office of the Federal Public Defender
                                                      500 East Main Street, Suite 500
                                                      Norfolk, Virginia 23510
                                                      Telephone: 757- 457-0850
                                                      Facsimile: 757-457-0880
                                                      Email: kirsten_kmet@fd.org

Case 2:23-cr-00135-EWH-LRL Document 19 Filed 01/22/24 Page 3 of 3 PageID# 59




                                 CERTIFICATE OF SERVICE

       I certify that on this 22nd of January 2024, I electronically filed the foregoing with the Clerk

of Court using the CM/ECF system, which will send a notification of such filing (NEF) to all

counsel of record.




                                                      _________/s/_______________

                                                      Kirsten R. Kmet
                                                      VSB No.: 47786
                                                      Assistant Federal Public Defender
                                                      Attorney for Maria Reich
                                                      Office of the Federal Public Defender
                                                      150 Boush Street, Suite 403
                                                      Norfolk, Virginia 23510
                                                      Telephone: 757-457-0850
                                                      Facsimile: 757-457-0880
                                                      Email: kirsten_kmet@fd.org

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