Unopposed Motion to Modify Conditions of Pretrial Release — United States of America v. Crystal Denean Harvell

Summary

Document 27, filed November 13, 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, this time asking for travel with permission by Pretrial Services. She wants to travel to Atlanta for work prospects and to Albany, Georgia to spend time with her daughter. She asks that paragraph (9)(D) of the release order (Doc. 10) keep restricting travel to the Middle District of Florida but let her Pretrial Services Officer approve travel, without the Court acting each time. The motion says Pretrial Services Officer Kimberly Barrett and Assistant United States Attorney Kevin Frein have no objection.

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“Unopposed Motion to Modify Conditions of Pretrial Release — United States of America v. Crystal Denean Harvell.” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-flmd-431431-27-0-8173f1fd72/, SHA-256 cb9a778f46382fed7f99a5524b3d861c985e0ee9f475ae9b3ea801a05ad6f02b.

Full text

Case 3:24-cr-00179-WWB-LLL Document 27 Filed 11/13/24 Page 1 of 3 PageID 85

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 WITH PERMISSION BY PRETRIAL
SERVICES

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 with permission by her Pretrial

Services Officer. 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 had discussions with her Pretrial Services Officer and

undersigned counsel regarding her desire to be able to travel to Atlanta for

1
Case 3:24-cr-00179-WWB-LLL Document 27 Filed 11/13/24 Page 2 of 3 PageID 86

work prospects and to Albany, Georgia, to spend time with her daughter.

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

be modified to continue to restrict her travel to the Middle District of Florida

but allow for that travel restriction to be modified by the Pretrial Services

Officer. This modification would allow Ms. Harvell to travel outside the Middle

District with permission from her Pretrial Services Officer and without

intervention of the Court each time she would like to travel to Georgia.

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

objections to the modification request, specifically she has no objections to

the specific conditions being modified to allow Ms. Harvell’s travel to be

modified by the Pretrial Services Officer.

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 27 Filed 11/13/24 Page 3 of 3 PageID 87

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 13th day of November 2024.

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

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