Unopposed Motion and Proposed Order Temporarily Modifying Conditions of Pretrial Release — United States v. Cassie Will-Darnall (Dkt. 106)

Summary

Defendant Cassie Will-Darnall, through the Federal Public Defender, files an unopposed motion and proposed order to temporarily modify the conditions of pretrial release. The motion asks permission to travel to Longview, Colorado, for a ski trip from December 17 to 23, 2025, for a personal vacation with a minor child. It states that counsel conferred with a Pretrial Services Officer and Assistant United States Attorney Sarah Griswold, and that neither objects. The proposed order would permit travel from San Jose to Longview, Colorado, and states that all other conditions remain in full effect. The motion is addressed to Hon. Virginia K. DeMarchi, and the order's date line is blank.

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Cite this document

“Unopposed Motion and Proposed Order Temporarily Modifying Conditions of Pretrial Release — United States v. Cassie Will-Darnall (Dkt. 106).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-cand-430212-106-0-27f4f5a181/, SHA-256 d058b5705443a359976a7fa8cd08faf3e840cbb530e85e16e21533e91bcab639.

Full text

Case 5:24-cr-00292-PCP Document 106 Filed 12/02/25 Page 1 of 2

1 JODI H. LINKER
Federal Public Defender
2
VARELL L. FULLER
3 Assistant Federal Public Defender
55 S. Market Street, Suite 820
4 San Jose, CA 95113
5
Telephone: (408) 291-7753
Varell_Fuller@fd.org
6
Counsel for Defendant WILL-DARNALL
7

8
UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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SAN JOSE DIVISION
11

12
UNITED STATES OF AMERICA, No. 24-CR-00292 PCP (VKD)
13
Plaintiff,
14 UNOPPOSED MOTION AND [PROPOSED]
v. ORDER TEMPORARILY MODIFYING
15 CONDITIONS OF PRETRIAL RELEASE
CASSIE WILL-DARNALL,
16
Defendant. Judge: Hon. Virginia K. DeMarchi
17

18 Defendant Cassie Will-Darnall, by and through counsel, respectfully requests that the

19 Court temporarily modify her pretrial release conditions to permit her to travel to Longview,
20
Colorado, for a ski trip from December 17 to 23, 2025. The purpose of Ms. Will-Darnall’s travel
21
is a personal vacation with her minor child. Counsel has conferred with Pretrial Services Officer
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Yaneyla Arevalo-Arellano and Assistant United States Attorney Sarah Griswold, and neither
23

24 objects to this modification.
25

26
//
27
//
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Motion to Temporarily Modify Conditions of Pretrial Release
WILL-DARNALL, 24-292 PCP
Case 5:24-cr-00292-PCP Document 106 Filed 12/02/25 Page 2 of 2

1 Dated: December 2, 2025 JODI H. LINKER
FEDERAL PUBLIC DEFENDER
2

3 __________/s/_______________
VARELL L. FULLER
4 Assistant Federal Public Defender
5

6 [PROPOSED] ORDER
7 GOOD CAUSE APPEARING, upon the defendant’s unopposed motion, IT IS HEREBY
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ORDERED that the defendant’s pretrial release conditions are temporarily modified to permit
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the defendant to travel from San Jose to Longview, Colorado from December 17, 2025 to
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11 December 23, 2025.

12 All other conditions are to remain in full effect.
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IT IS SO ORDERED.
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DATED: ___________ _________________________________________
15 THE HONORABLE VIRGINIA K. DEMARCHI
United States Magistrate Judge
16

Motion to Temporarily Modify Conditions of Pretrial Release
WILL-DARNALL, 24-292 PCP

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