Motion and Proposed Order Temporarily Modifying Conditions of Pretrial Release — United States v. Cassie Will-Darnall (Dkt. 37)

Summary

Defendant Cassie Will-Darnall, through counsel, moves to temporarily modify her pretrial release conditions so she can travel to Scottsdale, Arizona, from March 19, 2025, to March 26, 2025, to attend baseball spring training with her minor son and celebrate her recently deceased uncle's life. The motion recounts that she was ordered released on a $50,000 unsecured bond, that she entered an open plea on January 15, 2025, and that sentencing is scheduled for April 23, 2025. It states that the Pretrial Services Officer does not object, while the government is opposed to the temporary modification, and the defense offers to address the request at a hearing.

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“Motion and Proposed Order Temporarily Modifying Conditions of Pretrial Release — United States v. Cassie Will-Darnall (Dkt. 37).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-cand-430212-37-0-92d592dfb3/, SHA-256 4e54195196dd2e50e3381d6d202e69d74a671b49de316bc00c7cbaf40cba93b2.

Full text

Case 5:24-cr-00292-PCP Document 37 Filed 03/06/25 Page 1 of 3

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
9
NORTHERN DISTRICT OF CALIFORNIA
10
SAN JOSE DIVISION
11

12
UNITED STATES OF AMERICA, No. 24-CR-00292 PCP (SVK)
13
Plaintiff,
14 MOTION AND [PROPOSED] ORDER
vs. TEMPORARILY MODIFYING CONDITIONS
15 OF PRETRIAL RELEASE
CASSIE WILL-DARNALL,
16
Defendant. Judge: Hon. Susan van Kuelen
17

18 MOTION

19 Defendant Cassie Will-Darnall, by and through counsel, respectfully requests that the
20
Court temporarily modify her pretrial release conditions to permit her to travel to Arizona from
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March 19, 2025, to March 26, 2025. Ms. Will-Darnall respectfully requests permission to travel
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to Scottsdale, Arizona, to attend baseball spring training with her minor son and celebrate her
23

24 recently deceased uncle’s life. On May 30, 2024, Ms. Will-Darnall appeared on a summons,
25 waived indictment in this matter, and made her initial appearance. Dkt. No. 3. She was ordered
26
released on a $50,000 unsecured bond and surrendered her passport to Pretrial Services. On
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January 15, 2025, Ms. Will-Darnall entered an open plea. Sentencing in this matter is scheduled
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for April 23, 2025. On February 8, 2025, Ms. Will-Darnell’s maternal uncle, Nicholas Peter
Motion to Temporarily Modify Conditions of Pretrial Release
WILL-DARNALL, 24-CR-292 PCP (SVK)
Case 5:24-cr-00292-PCP Document 37 Filed 03/06/25 Page 2 of 3

1 Skalkos, Jr. passed in Maine, and a service was later held in Connecticut. Counsel for Ms. Will-
2
Darnell is reasonably informed that Mr. Skalkos was a baseball fan and regularly attended spring
3
training games in Scottsdale, Arizona, with Ms. Will-Darnall and her son. The purpose of Ms.
4

5
Will-Darnall’s trip is to attend spring training and celebrate her deceased uncle's life with her

6 minor child. Ms. Will-Darnall has no prior criminal history, and has been on pretrial release for
7 approximately nine months without incident. She has attended all court proceedings as
8
ordered and has complied with her pretrial release conditions as ordered.
9
Counsel for Ms. Will-Darnall has conferred with Pretrial Services Officer Yaneyla
10

11 Arevalo Arellano, and she does not object to this modification. Defense counsel also conferred

12 with Special Assistant United States Attorney Johnny James, and the government is opposed to
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this temporary modification. Given the government’s position, the defense is prepared to further
14
address Ms. Will-Darnall’s travel request at a hearing on the matter, should the court determine
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a hearing is necessary. For the foregoing reasons, the defense respectfully requests that the court
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17 grant Ms. Will-Darnall’s travel request.

19
Dated: March 6, 2025, JODI H. LINKER
20 FEDERAL PUBLIC DEFENDER

21 __________/s/_______________
22
VARELL L. FULLER
Assistant Federal Public Defender
23

Motion to Temporarily Modify Conditions of Pretrial Release
WILL-DARNALL, 24-CR-292 PCP (SVK)
Case 5:24-cr-00292-PCP Document 37 Filed 03/06/25 Page 3 of 3

2
[PROPOSED] ORDER
3
GOOD CAUSE APPEARING, upon the defendant’s motion, IT IS HEREBY
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ORDERED that the defendant’s pretrial release conditions are temporarily modified to permit

6 the defendant to travel from San Jose to Arizona, from March 19, 2025, to March 26, 2025.
7 All other conditions are to remain in full effect.
8
IT IS SO ORDERED.
9
DATED: ___________ _________________________________________
10
THE HONORABLE SUSAN van KUELEN
11 United States Magistrate Judge

Motion to Temporarily Modify Conditions of Pretrial Release
WILL-DARNALL, 24-CR-292 PCP (SVK)

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