Amended Memorandum Regarding Release on Conditions, Case 4:20-cr-00583 (Dkt. 34, S.D. Tex.)

Summary

This amended memorandum regarding release on conditions, Document 34 filed November 23, 2020 in United States v. Amir Aqeel, Case 4:20-cr-00583 in the U.S. District Court for the Southern District of Texas, is addressed to Judge Sheldon by defense counsel Mark Bennett. It states that Mr. Aqeel has lived in the district for 28 years, owns two houses there, supports eight dependents, and returned to the United States after the government seized the defendant's electronic devices in Turkey. It cites a 2009 Harris County case in which deferred-adjudication probation was completed in August 2013. It argues that the U.S. Probation Office's proposed conditions, including passport surrender, GPS monitoring and travel restricted to the district, will reasonably ensure appearance and safety. Exhibit A is a Harris County order dated 08/28/2013 terminating community supervision.

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Case 4:20-cr-00583 Document 34 Filed on 11/23/20 in TXSD Page 1 of 4
Cause No. 4:20-CR-583
United States of America United States District Court
v. Southern District of Texas
Amir Aqeel Houston Division
Amended Memorandum Regarding
Release on Conditions

Judge Sheldon:

Mr. Aqeel’s ties to the Southern District of Texas are wide and deep.

He has lived in the United states since he was 18 years old, and in the

Southern District of Texas for 28 years. He owns two houses here. He

lives in one of them with his wife, daughter, and mother-in-law; and his
ex-wife lives in the other house with their four children under age 20.

Mr. Aqeel is the sole source of support for those eight dependents.

His ex-wife does not work, and his wife, a registered nurse, is currently
on medical leave recovering from a back injury, and is homeschooling

their daughter due to covid-19.

Mr. Aqeel is a successful self-employed businessman. He has current

and active Texas insurance licenses, as well as an IRS Preparer Tax

Identification Number, and has been in the insurance and accounting

businesses for twenty years.
On Mr. Aqeel’s last trip abroad, the U.S. Government seized Mr.

Aqeel’s electronic devices in Turkey when he was on his way to

Pakistan. Still, knowing that he was being investigated, Mr. Aqeel
returned to the United States.
Case 4:20-cr-00583 Document 34 Filed on 11/23/20 in TXSD Page 2 of 4

Mr. Aqeel is a United States Citizen who has made a home in

Houston.

Mr. Aqeel had a criminal case in Harris County in 2009 (the pretrial

officer missed this, but the Government provided Counsel with notice),

and he faithfully attended court for 18 months, from December 2009 to

June 2011, before taking deferred-adjudication probation, which he

successfully completed in August 2013.
Mr. Aqeel responded well to supervision for 44 months.

The conditions proposed by the U.S. Probation Office will reasonably

ensure Mr. Aqeel’s appearance and the safety of the community.
Any concerns about flight risk will be resolved by surrender of Mr.

Aqeel’s passport, GPS monitoring, and travel restricted to this District.

Any concerns about danger to the community will be resolved by the
usual condition against contact with codefendants and opening new

bank accounts.

2
Case 4:20-cr-00583 Document 34 Filed on 11/23/20 in TXSD Page 3 of 4

Thank you,

______________________
Mark Bennett
SBN 00792970
Bennett & Bennett
917 Franklin Street, Fourth Floor
Houston, Texas 77002
713.224.1747
mb@ivi3.com

3
Case 4:20-cr-00583 Docausennd4 1241728, 11/23/20 in TXSD_ Page 4 of 4

Ageel Bail Memo
THE STATE OF TEXAS Exhibit A
—T_Amir Agee! | aka | |
DISTRICT COURT
HARRIS COUNTY, TEXAS
ORDER AFFECTING COMMUNITY SUPERVISION NG

After considering the community supervision officer’s recommendations and other evidence, eo Gasiding judge FINDS that

the Defendant: ©

wi has satisfactory fulfilled the condition of supervision imposed by the court unde? the Texas Code of Criminal
Procedure and/or Chapter 481 of the Texas Health and Safety Code.

G has not satisfactorily fulfilled the conditions of supervision imposed b £0 cour under the Texas Code of
Criminal Procedure and/or Chapter 481 of the Texas Health and Safety cede ee Comment section below).

Motion Denied [The Defendant has not satisfactorily fulfilled the itions of community supervision imposed
by the Court for the term of the supervision period to which he/she was sentenced.

Accordingly, the Court ORDERS defendant’s motion to terminate comunity supervision denied.
Date signed: [ S
wv Judge Presiding, L__istrict Court
C Harris County, Texas

Full Term [1 The Defendant hag Satistactoriy fulfilled the conditions of supervision imposed by the
Court for th ees érm of the supervision period to which he/she was sentenced.

Early Termination [i The Defe t has satisfactorily fulfilled the conditions of supervision imposed by the

(Permissive review) Court fartwo (2) years or for more than one-third (1/3) of the time to which defendant

was ente ced to community supervision.

Deferred Adjudication My fadest interests of the defendant and society will be served by the early termination of
Early Termination “defendant's supervision period. The Court has not proceeded to an adjudication of guilt
os Curing the period of supervision.

Deferred Adjudication’ C The Defendant has satisfactorily fulfilled the conditions of supervision imposed by the
Full Term © Court for the full term of the supervision period to which he/she was sentenced. The
SS Court has not proceeded to an adjudication of guilt during the period of supervision.

Comments: Gi | |

Accordingly, the Court ORDERS defendant’s community supervision terminated. The Coyft further ORDE
AND DECREES that the defendant is discharged according to law.

, ADJUDGES

08/28/2013

Date signed:

'S MEMORANDUM
REO of poor qually udge Presiding, 228thlpistr ct Court
at the time of imaging Harris County, Texas

Revised September 1, 2009 LY OQ 4 evan

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