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Defendant’s Motion to Allow Defendant to Leave the State — No. 0:20-cr-00261 (Dkt. 26, D. Minn.)

Summary

A defendant's motion to allow the defendant to leave the state, filed in the U.S. District Court for the District of Minnesota in United States v. Aditya Raj Sharma, Cr. No. 20-261 (DSD/TNL), docketed as 0:20-cr-00261, as Doc. 26 of 2 pages. Sharma asks permission to leave Minnesota for Mesa, Arizona for three nights within the next couple of weeks, for work, to meet a company to execute a trial of the KloudGaze software, flying there and back. Probation Officer Krystal Taylor confirmed his compliance with all pretrial release conditions and does not object, and Assistant U.S. Attorney Matthew Ebert defers to her. The motion notes that on November 16, 2020 the Honorable Hildy Bowbeer set conditions of release at ECF No. 7, including no travel outside Minnesota without Court approval, and that Sharma will not buy flights or a hotel until the request is granted.

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Cite this document

“Defendant’s Motion to Allow Defendant to Leave the State — No. 0:20-cr-00261 (Dkt. 26, D. Minn.).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/defendant-s-motion-to-allow-defendant-to-leave-the-state-no-0-20-cr-00-aa08f4037f/, SHA-256 c7415a3d5d93a9e69d4e6cd5a8450fc1736236d3c470b6cb143fdec24989155e.

Full text

           CASE 0:20-cr-00261-DSD-TNL Doc. 26 Filed 02/11/21 Page 1 of 2




                              UNITED STATES DISTRICT COURT
                                 DISTRICT OF MINNESOTA
                                  Cr. No. 20-261 (DSD/TNL)

UNITED STATES OF AMERICA,                          )
                                                   )
                         Plaintiff,                )
                                                   )       DEFENDANT’S MOTION TO
                 v.                                )       ALLOW DEFENDANT TO
                                                   )       LEAVE THE STATE
ADITYA RAJ SHARMA,                                 )
                                                   )
                         Defendant.                )


        The purpose of this motion is to request that Mr. Sharma be permitted to leave

Minnesota for Arizona for three nights. Probation Officer Krystal Taylor confirmed that

Mr. Sharma has complied with all pretrial release conditions, and she has no objection to

Mr. Sharma’s travel request. Assistant U.S. Attorney Matthew Ebert defers to Ms.

Taylor’s position on the matter. Thus, he does not object.

        On November 16, 2020, the Honorable Hildy Bowbeer set conditions of release in

Mr. Sharma’s case (ECF No. 7). One such condition is to not travel outside of Minnesota

without Court approval (id. at p. 2). Mr. Sharma seeks to travel to Mesa, Arizona for

work purposes for three nights within the next couple of weeks. He will fly from

Minnesota to Arizona and back.1 The purpose of the trip is to meet with a company to

execute a trial of the KloudGaze software.




1
  Mr. Sharma will not purchase his flight or hotel unless this Court grants his travel request. Upon his
purchase, he will provide all the details, including the specific dates, flight information, hotel information,
etc., to his pretrial services agent, Krystal Taylor.
        CASE 0:20-cr-00261-DSD-TNL Doc. 26 Filed 02/11/21 Page 2 of 2




      Mr. Sharma’s work commitment requires two full business days, and with the

uncertainty of flights, he intends to fly down one day before the meeting. We ask that the

Court grant permission to allow Mr. Sharma to travel to Arizona for three nights to

accommodate this business trip.



                                          Respectfully submitted,

                                          RYAN GARRY, ATTORNEY, LLC



Dated: February 11, 2021                  s/ Elizabeth Duel
                                          Ryan P. Garry (Attorney No. 0336129)
                                          Elizabeth R. Duel (Attorney No. 0393619)
                                          Attorneys for Defendant
                                          333 South Seventh Street, Suite 2350
                                          Minneapolis, MN 55402
                                          Phone: (612) 436-3051
                                          Fax: (612) 436-3052
                                          ryan@ryangarry.com | elizabeth@ryangarry.com




                                          BIRRELL LAW FIRM, PLLC

                                          Andrew S. Birrell (Attorney No. 133760)
                                          Attorneys for Defendant
                                          333 South 7th Street, Suite 2350
                                          Minneapolis, MN 55402
                                          Phone: (612) 238-1939
                                          andy@birrell.law




                                            2

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26.pdf
Size
72,388 bytes
SHA-256
c7415a3d5d93a9e69d4e6cd5a8450fc1736236d3c470b6cb143fdec24989155e
Our copy
26.pdf
Original
archive.org
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