Unopposed Motion to Modify Conditions of Pretrial Release (Travel) — Case 3:24-cr-00179, Document 20

Summary

Document 20, filed September 12, 2024 in Case No. 3:24-cr-179-WWB-LLL in the U.S. District Court for the Middle District of Florida, Jacksonville Division, is an Unopposed Motion to Modify Conditions of Pretrial Release in United States of America v. Crystal Denean Harvell. Her counsel asks to modify the travel restriction in paragraph (9)(D) of the release order (Doc. 10) so she can travel outside the Middle District of Florida from October 17, 2024 through October 20, 2024. The stated purpose is to visit her daughter in college in Albany, Georgia and attend homecoming events. The motion says Pretrial Services Officer Kimberly Barrett and Assistant United States Attorney Kevin Frein have no objection. It cites 18 U.S.C. § 3142(c).

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“Unopposed Motion to Modify Conditions of Pretrial Release (Travel) — Case 3:24-cr-00179, Document 20.” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-flmd-431431-20-0-22880a1892/, SHA-256 4a66adaa5f4d2b0bbbbe4258ecc733d441580e30c8178a99dc30eba707fac91f.

Full text

Case 3:24-cr-00179-WWB-LLL Document 20 Filed 09/12/24 Page 1 of 3 PageID 68

UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
JACKSONVILLE DIVISION

UNITED STATES OF AMERICA

v. Case No. 3:24-cr-179-WWB-LLL

CRYSTAL DENEAN HARVELL
/

UNOPPOSED MOTION TO
MODIFY CONDITIONS OF PRETRIAL RELEASE – TRAVEL OUTSIDE OF THE
MIDDLE DISTRICT OF FLORIDA

Defendant, Crystal Denean Harvell, by and through undersigned counsel,

hereby moves this Court to modify the conditions of her pretrial release and allow

her to travel outside the Middle District of Florida from October 17, 2024, through

October 20, 2024. In support of this Motion, Ms. Harvell states the following:

1. On September 4, 2024, Ms. Harvell appeared in the Middle District of Florida

for an initial appearance and was released on standard and special

conditions of pretrial release, which are listed in the Order Setting Conditions

of Release (Doc. 10).

2. Paragraph (9)(D) of the original Order states that Ms. Harvell’s “…travel is

restricted to the Middle District of Florida” (Doc. 10).

3. Ms. Harvell has indicated that she would like to visit her daughter who is in

college at Albany State University in Albany, Georgia, and attend her

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Case 3:24-cr-00179-WWB-LLL Document 20 Filed 09/12/24 Page 2 of 3 PageID 69

homecoming events. Ms. Harvell is planning on staying with her daughter at

the University Apartments, 400 Radium Springs Road, Apartment 3102,

Albany, Georgia 3102. She would like to travel to Albany, Georgia on

October 17, 2024, and return to the Middle District of Florida on October 20,

2024.

4. Ms. Harvell requests that Specific Condition (9)(D) of the Special Conditions

be modified to allow her to travel outside the Middle District of Florida from

October 17, 2024 through October 20, 2024, for the purpose of visiting her

daughter in Albany, Georgia, which is in the Middle District of Georgia.

5. Pretrial Services Officer Kimberly Barrett has been contacted and has no

objections to Ms. Harvell traveling to visit her daughter in college.

6. Undersigned counsel discussed this matter with Assistant United States

Attorney Kevin Frein, and he has no objection to this Motion.

7. Therefore, Ms. Harvell respectfully requests that this Court issue an order

modifying the travel restrictions set forth in the Order Setting Conditions of

Release.

MEMORANDUM OF LAW

This Court has numerous options in setting conditions of pretrial release that

“will reasonably assure the appearance of the person as required and the safety

of any other person and the community.” 18 U.S.C. § 3142(c)(1)(B). This Court

“may at any time amend the order to impose additional or different conditions of
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Case 3:24-cr-00179-WWB-LLL Document 20 Filed 09/12/24 Page 3 of 3 PageID 70

release.” 18 U.S.C. § 3142(c)(3).

A. FITZGERALD HALL, ESQ.
FEDERAL DEFENDER, MDFL

s/ Sabra M. Barnett
Sabra M. Barnett, Esq.
Alabama Bar No. 8834R69W
Assistant Federal Defender
200 West Forsyth Street, Suite 1240
Jacksonville, FL 32202
Telephone: (904) 232-3039
Fax: (904) 232-1937
Email: sabra_barnett@fd.org

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a copy of the foregoing has been furnished by

electronic notification to the Office of the United States Attorney, 300 N. Hogan St,

Suite 700, Jacksonville, Florida 32202, this 12th day of September 2024.

s/ Sabra M. Barnett
Sabra M. Barnett, Esq.
Assistant Federal Defender

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