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Unopposed Motion and Proposed Order Temporarily Modifying Conditions of Pretrial Release — United States v. Cassie Will-Darnall (Dkt. 70)

Summary

Document 70, filed 06/24/25, repeats the unopposed motion in United States v. Cassie Will-Darnall asking leave for pretrial-release travel in July 2025. The requested trips are to Boston (July 7 to July 10), Baltimore (July 11 to July 13) and Atlanta (July 13 to July 16), described as a personal vacation to attend baseball games. The motion reports that the Pretrial Services Officer and a Special Assistant United States Attorney do not object. This copy of the proposed order carries the date June 24, 2025 above the name of Magistrate Judge Van Kuelen and keeps all other release conditions 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. 70).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-cand-430212-70-0-33302fa171/, SHA-256 57e9edacc96baf21134cc41f18f46cb18b84818ae556cb92fe8ab47587745f22.

Full text

            Case 5:24-cr-00292-PCP          Document 70        Filed 06/24/25     Page 1 of 2



 1   JODI LINKER, Bar No. 230273
     Federal Public Defender
 2   Northern District of California
     VARELL FULLER, Bar No. 202680
 3   Assistant Federal Public Defender
     8th Floor - Suite 820
 4
     55 South Market Street
 5   San Jose, CA 95113
     Telephone: (408) 291-7753
 6   Facsimile: (408) 291-7399
     Email:        Varell_Fuller@fd.org
 7

 8   Counsel for Defendant WILL-DARNALL
 9

10                                 IN THE UNITED STATES DISTRICT COURT
11                           FOR THE NORTHERN DISTRICT OF CALIFORNIA
12                                           SAN JOSE DIVISION
13

14    UNITED STATES OF AMERICA,                             Case No. CR 24–00292 PCP
15                    Plaintiff,                            UNOPPOSED MOTION AND
                                                            [PROPOSED] ORDER TEMPORARILY
16            v.                                            MODIFYING CONDITIONS OF
                                                            PRETRIAL RELEASE
17    CASSIE WILL-DARNALL,
18                    Defendant.
19

20                                                     MOTION
21         Defendant Cassie Will-Darnall, by and through counsel, respectfully requests that the Court
22   temporarily modify her pretrial release conditions to permit the following travel from San Jose,
23   California:
24         1) Boston, Massachusetts, located in the District of Massachusetts, from July 7, 2025, to July
25             10, 2025;
26         2) Baltimore, Maryland, located in the District of Maryland, from July 11, 2025, to July 13,
27             2025; and
28         3) Atlanta, Georgia, located in the Northern District of Georgia, from July 13, 2025, to July

     UNOPPOSED MOTION AND [PROPOSED] ORDER TEMPORARILY MODIFYING CONDITIONS OF PRETRIAL RELEASE
     WILL-DARNALL, CR 24–00292 PCP
                                                        1
            Case 5:24-cr-00292-PCP          Document 70         Filed 06/24/25      Page 2 of 2



 1             16, 2025.
 2         The purpose of Ms. Will-Darnall’s travel is for a personal vacation to attend baseball games in
 3   the respective cities. Counsel for Ms. Will-Darnall has conferred with Pretrial Services Officer
 4   Yaneyla Arevalo Arellano and Special Assistant United States Attorney Johnny James, and they do
 5   not object to this modification.
 6

 7        Dated:    June 24, 2025                            Respectfully submitted,

 8                                                           JODI LINKER
                                                             Federal Public Defender
 9                                                           Northern District of California
10                                                                     /S
                                                             VARELL FULLER
11
                                                             Assistant Federal Public Defender
12

13                                           [PROPOSED] ORDER
14         GOOD CAUSE APPEARING, and upon the defendant’s unopposed motion, IT IS HEREBY
15   ORDERED that the defendant’s pretrial release conditions are temporarily modified to permit the
16   following travel:
17         1) Boston, Massachusetts, located in the District of Massachusetts, from July 7, 2025, to July
18             10, 2025;
19         2) Baltimore, Maryland, located in the District of Maryland, from July 11, 2025, to July 13,
20             2025; and
21         3) Atlanta, Georgia, located in the Northern District of Georgia, from July 13, 2025, to July
22             16, 2025.
23         All other conditions of release shall remain in full effect.
24         IT IS SO ORDERED.
25 DATED:____
          June 24, 2025                                   ______________________________________
26                                                        HON. SUSAN VAN KUELEN
                                                          United States Magistrate Judge
27

28

     UNOPPOSED MOTION AND [PROPOSED] ORDER TEMPORARILY MODIFYING CONDITIONS OF PRETRIAL RELEASE
     WILL-DARNALL, CR 24–00292 PCP
                                                         2

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