Defendant’s Motion to Modify Order Setting Conditions of Release — No. 4:26-cr-00174 (Dkt. 134, E.D. Mo.)

Summary

A defendant's motion to modify the order setting conditions of release, filed in the U.S. District Court for the Eastern District of Missouri, Eastern Division, in United States v. Dana Kelly, Case No. 4:26-cr-00174, as filing 134 of 3 pages, dated July 7, 2026. Attorney Dramon M. Foster asks the Court to let Kelly travel outside the Eastern District of Missouri to Illinois. He states that on April 20, 2026 she appeared before Hon. John M. Bodenhausen, United States Magistrate Judge, and was granted pretrial release under conditions at Doc. No. 61, one of which restricts travel to the district without Court permission, that she earns income driving for Uber, lives 3 miles from the State of Illinois and is likely to get rides into it, and that she would like to seek jobs there. Counsel has discussed the request with pretrial officer Lauren Gilkeson.

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Case: 4:26-cr-00174-MTS-JMB             Doc. #: 134        Filed: 07/07/26      Page: 1 of 3 PageID
                                              #: 409



                             UNITED STATES DISTRICT COURT
                             EASTERN DISTRICT OF MISSOURI
                                   EASTERN DIVISION


UNITED STATES OF AMERICA,                               )
Plaintiff,                                              )
                                                        ) Case No: 4:26-cr-00174-MS-JMB-4
                                                        )
v.                                                      )
                                                        )
DANA KELLY,                                             ) July 7, 2026
Defendant.                                              )
                                                        )

      DEFENDANT’S MOTION TO MODIFY ORDER SETTING CONDITIONS OF
                              RELEASE

        COMES NOW attorney Dramon M. Foster, on behalf of the Defendant, Dana Kelly, and

requests that this Court modify the Order Setting Conditions of Release to allow Ms. Kelly to

travel outside of the Eastern District of Missouri to Illinois. In support thereof, Counsel states:

     1. On April 20, 2026, Ms. Kelly appeared before the Hon. John M. Bodenhausen, United

        States Magistrate Judge, for her initial appearance, arraignment, and bond execution

        hearing.

     2. Ms. Kelly was granted pretrial release subject to various conditions. See Doc. No. 61.

        One such condition is that Ms. Kelly’s “Travel restricted to the Eastern District of

        Missouri with travel outside the district only allowed with Court permission.”

     3. Ms. Kelly is currently doing Uber as a means of income. She lives 3 miles from the State

        of Illinois and it is likely she will get rides into the State. She would also like to seek

        additional job opportunities in Illinois.

     4. Counsel has discussed this matter with Ms. Kelly’s pretrial officer, Lauren Gilkeson, who

        indicated she had no objection to modifying Ms. Kelly’s conditions to allow her to travel
Case: 4:26-cr-00174-MTS-JMB            Doc. #: 134      Filed: 07/07/26      Page: 2 of 3 PageID
                                             #: 410



       outside of the Eastern District of Missouri into the state of Illinois for work purposes.

   5. Accordingly, Ms. Kelly requests that Section 7, part (f) of the order setting conditions of

       release be amended as follows:



               Defendant’s travel is restricted to the Eastern District of Missouri with travel

               outside the district only allowed with Court permission, except for travel to the

               State of Illinois for work purposes.



       WHEREFORE, for the reasons stated above, defendant requests the Order Setting

Conditions of Release (Doc No. 61) be modified to allow for her to enter the State of Illinois for

work purposes.




                                              RESPECTFULLY SUBMITTED,

                                              /s/ Dramon M. Foster
                                              Dramon M. Foster, #56546
                                              The Foster Law Firm, LLC
                                              3703 Watson Road,
                                              St. Louis, MO 63109
                                              Phone: (314) 517-3274
                                              Fax: (314) 584-5010
                                              Email: dramonesq@yahoo.com
Case: 4:26-cr-00174-MTS-JMB            Doc. #: 134       Filed: 07/07/26      Page: 3 of 3 PageID
                                             #: 411



                                 CERTIFICATE OF SERVICE

Signature of the foregoing is also certification that the foregoing was filed electronically with the
Clerk of the United States District Court for the Easter District of Missouri to be served by
operation of the electronic filing system upon the United States Attorney’s Office, this 7th day of
July 2026.


                                              /s/ Dramon M. Foster
                                              Dramon M. Foster


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