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Motion to Modify Conditions of Release — United States v. Sherrie Bryant (D. Md., Dkt. 54)

Summary

Defendant's Motion to Modify Conditions of Release, filed February 6, 2023 as Document 54, Case 8:22-cr-00308-DLB, United States v. Sherrie Bryant, District of Maryland. The motion states that the Court sentenced Ms. Bryant on January 26 and granted permission to self-surrender, and that before surrender the Defendant wishes to refinance a home. It states that pretrial services officer Ms. McWilson does not object but requested Court approval, and that the government defers to the Court. It states the Defendant is willing to submit loan documents to pretrial for review if requested, and asks the Court to modify the conditions of release to engage in a mortgage refinancing. It is signed /s/ Charles Burnham, attorney for the Defendant.

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“Motion to Modify Conditions of Release — United States v. Sherrie Bryant (D. Md., Dkt. 54).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-d-md-no-8-22-cr-00308-dkt-54-d-md-5d3902ee49/, SHA-256 66b485cba55b9ca0a92d7aa932793d8b17120c155a3b8945acd229dc72f7595c.

Full text

      Case 8:22-cr-00308-DLB Document 54 Filed 02/06/23 Page 1 of 3



    IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF
                           MARYLAND


                                    )
United States                       )
                                    )
                v.                  )              No. 8:22cr308
                                    )
Sherrie Bryant,                     )
                                    )
                                    )
       Defendant.                   )

                  MOTION TO MODIFY CONDITIONS OF RELEASE

     Comes now the Defendant Sherrie Bryant and moves to amend her conditions of

release. Ms. Bryant submits as follows:

   1. This Court sentenced Ms. Bryant on January 26 and granted her permission to self-

       surrender.

   2. Prior to her surrender, Ms. Bryant wishes to refinance her home in connection with

       state family law proceedings discussed with the Court at sentencing.

   3. Ms. Bryant has discussed the need to conduct this refinance with her pretrial

       services officer Ms. McWilson. Ms. McWilson does not object to the refinance but

       requested we seek Court approval.

   4. Undersigned counsel has discussed this request with counsel for the government.

       The government defers to the Court.

   5. Ms. Bryant is prepared to execute this transaction with complete transparency with

       pretrial. She is willing to submit loan documents to pretrial for their review if

       requested. A proposed order is included.
      Case 8:22-cr-00308-DLB Document 54 Filed 02/06/23 Page 2 of 3



      For the foregoing reasons Ms. Bryant requests the Court to modify her conditions of

release to engage in a mortgage refinancing.



                                                    Respectfully Submitted,

                                                    By:



                                                    /s/ Charles Burnham
                                                    Charles Burnham, DC # 1003464
                                                    Attorney for the Accused
                                                    Burnham & Gorokhov, PLLC
                                                    1424 K St. NW, Suite 500
                                                    Washington, DC 20005
                                                    (202) 386-6920 (phone)
                                                    (202) 765-2173 (fax)
                                                    charles@burnhamgorokhov.com




                             CERTIFICATE OF SERVICE

       I hereby certify that a copy of this pleading was filed on opposing counsel through

the Court’s electronic filing system.

By: /s/ Charles Burnham
Charles Burnham
D.C. Bar 1003464
Attorney for Defendant
BURNHAM & GOROKHOV, PLLC
1424 K Street NW, Suite 500
Washington, DC 20005
(202) 386-6920 (phone)
(202) 265-2173 (fax)
     Case 8:22-cr-00308-DLB Document 54 Filed 02/06/23 Page 3 of 3



Charles@burnhamgorokhov.com


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