Unopposed Motion and Proposed Order Temporarily Modifying Conditions of Pretrial Release — United States v. Cassie Will-Darnall (Dkt. 23)
Summary
Defendant Cassie Will-Darnall, through counsel, files an unopposed motion and proposed order temporarily modifying her conditions of pretrial release. She asks to travel to Virginia from September 19, 2024, to September 22, 2024, to accompany her minor child on a visit to the NASA Air and Space Center in Hampton, Virginia. Counsel states that Pretrial Services Officer Emily Sanchez and Assistant United States Attorney Sarah Griswold do not object. The proposed order would permit travel from San Jose to Virginia for those dates, with all other conditions remaining in full effect.
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“Unopposed Motion and Proposed Order Temporarily Modifying Conditions of Pretrial Release — United States v. Cassie Will-Darnall (Dkt. 23).”
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Case 5:24-cr-00292-PCP Document 23 Filed 09/17/24 Page 1 of 2
1 JODI H. LINKER
Federal Public Defender
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VARELL L. FULLER
3 Assistant Federal Public Defender
55 S. Market Street, Suite 820
4 San Jose, CA 95113
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Telephone: (408) 291-7753
Varell_Fuller@fd.org
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Counsel for Defendant WILL-DARNALL
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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SAN JOSE DIVISION
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UNITED STATES OF AMERICA, No. 24-CR-00292 PCP (SVK)
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Plaintiff,
14 UNOPPOSED MOTION AND [PROPOSED]
vs. ORDER TEMPORARILY MODIFYING
15 CONDITIONS OF PRETRIAL RELEASE
CASSIE WILL-DARNALL,
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Defendant. Judge: Hon. Susan van Kuelen
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18 Defendant Cassie Will-Darnall, by and through counsel, respectfully requests that the
19 Court temporarily modify her pretrial release conditions to permit her travel to Virginia from
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September 19, 2024, to September 22, 2024, to accompany her minor child on a visit to the
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NASA Air and Space Center, located in Hampton, Virginia.
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Counsel for Ms. Will-Darnall has conferred with Pretrial Services Officer Emily Sanchez
24 and Assistant United States Attorney Sarah Griswold, and they do not object to this
25 modification.
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Motion to Temporarily Modify Conditions of Pretrial Release
WILL-DARNALL, 24-CR-292 PCP
Case 5:24-cr-00292-PCP Document 23 Filed 09/17/24 Page 2 of 2
1 Dated: September 17, 2024 JODI H. LINKER
FEDERAL PUBLIC DEFENDER
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3 __________/s/_______________
VARELL L. FULLER
4 Assistant Federal Public Defender
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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 Virginia, from September 19, 2024, to September 22,
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11 2024.
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 SUSAN van KUELEN
United States Magistrate Judge
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Motion to Temporarily Modify Conditions of Pretrial
Release WILL-DARNALL, 24-CR-292 PCP
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