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Consent Motion for Modification of Conditions of Pre-Trial Release — No. 8:23-cr-00376 (Dkt. 86, D. Md.)

Summary

A consent motion for modification of conditions of pre-trial release filed in the U.S. District Court for the District of Maryland, Southern Division, in United States v. Terry Chen, Criminal Case No. DLB23-376, docketed as 8:23-cr-00376 and entered as Document 86. Through counsel Marc G. Hall, Chen, who is released to the supervision of pre-trial services with home detention and is described as in compliance with all requirements, asks the Court to let him travel with his family to Edison and Bayview, New Jersey for Christmas, leaving December 24, 2024 and returning December 29, 2024, to visit his grandparents in Bayview and cousins in Edison. The motion states he will remain in the District of New Jersey at an address provided to and approved by U.S. Pretrial Services, and that the government consents; it was served by ECF on the United States Attorney's Office.

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Cite this document

“Consent Motion for Modification of Conditions of Pre-Trial Release — No. 8:23-cr-00376 (Dkt. 86, D. Md.).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/consent-motion-for-modification-of-conditions-of-pre-trial-release-no-a8d3909513/, SHA-256 7099dc37768c767a9ea5f5c334ec996e291f023d1b541fc8e514200c15415141.

Full text

        Case 8:23-cr-00376-DLB           Document 86      Filed 12/11/24     Page 1 of 3



                    IN THE UNITED STATES DISTRICT COURT
                        FOR THE DISTRICT OF MARYLAND
                                        SOUTHERN DIVISION

UNITED STATES OF AMERICA                        *


v.                                              * Criminal Case No. DLB23-376


TERRY CHEN,                                     *

                                                *
     CONSENT MOTION FOR MODIFICATION OF CONDITIONS OF PRE-TRIAL
                             RELEASE


        COMES NOW, the Defendant, Terry Chen, by and through his undersigned counsel, Marc

G. Hall, Esquire requesting this Court Grant a modification of the conditions of pre-trial release

and allow him to travel to New Jersey with his family for Christmas and for reasons states the

following:

        1. The Defendant currently is released to the supervision of pre-trial services with home

detention.

        2. Currently Mr. Chen is in compliance with all the requirements of pre-trial services and

with no violations of his pretrial release.

        3. Mr. Chen lives with his family in the Oxon Hill area of Prince Georges County,

Maryland.

        4. Mr. Chen family will be travelling to Edison and to Bayview, New Jersey for Christmas

to visit other family members leaving December 24, 2024, and returning December 29, 2024. From

December 24, 2024, until December 29, 2024. His grandparents live in Bayview, and he has
        Case 8:23-cr-00376-DLB          Document 86      Filed 12/11/24        Page 2 of 3



cousins in Edison, NJ. Mr. Chen will remain in the District of New Jersey and reside at an address

that has been provided to and approved by U.S. Pretrial Services.

       5. Counsel spoke to the Assistant United States Attorney, Harry Gruber, who is assigned

to this case, and he consents to this motion. The Defendant’s Pre-Trial Officer Pamela Nieva has

indicated he has no objection to his travel plans.

       WHEREFORE, for these reasons the Defendant, Mr. Chen requests that the Court allow

him to travel to Edison and to Bayview, New Jersey with his family for Christmas leaving on

December 24 and returning on December 29, 2024.




                                                     Respectfully submitted,

                                                     Law Office of Marc G. Hall, P.C.



                                                            /S/
                                                     Marc G. Hall, Esquire (#01386)
                                                     6411 Ivy Lane
                                                     Suite 150
                                                     Greenbelt, MD 20770
                                                     240 205-3041
                                                     Attorney for the Defendant




                                 CERTIFICATE OF SERVICE

      I HEREBY CERTIFY that on this 11th day of December 2024, a copy of the foregoing
document was electronically transmitted through ecf to the United States Attorney’s Office,
Greenbelt, Baltimore, Maryland 21201.
Case 8:23-cr-00376-DLB   Document 86   Filed 12/11/24   Page 3 of 3




                                        /S/
                                  Marc G. Hall, Esquire (#01386)

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86.pdf
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99,338 bytes
SHA-256
7099dc37768c767a9ea5f5c334ec996e291f023d1b541fc8e514200c15415141
Our copy
86.pdf
Original
archive.org
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