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Motion to Modify Conditions of Bond — United States v. Rosalie Clement-Jackson (District of Massachusetts)

Summary

A Motion to Modify Conditions of Bond, Document 49, filed March 27, 2026 in Criminal Case #26-10030-RGS-JCB in the United States District Court for the District of Massachusetts, by defendant Rosalie Clement-Jackson. It asks to modify condition #2 of the bond conditions ordered by the Southern District of Florida, which bars travel outside the Southern District of Florida unless the Court approves in advance, ordered by Magistrate Judge Panayotta on February 9, 2026 in Criminal Docket #0:26-mj-06063-PAB. The defendant proposes to travel by automobile to Tallahassee, Florida for a visit to Florida A&M University. The motion states that AUSA Kristen Kearney and Probation Officer Mackenzie Hilaire express "no objection".

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“Motion to Modify Conditions of Bond — United States v. Rosalie Clement-Jackson (District of Massachusetts).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-mad-295477-49-0-485aaad6d1/, SHA-256 dbe07409e1df558b8d3ee301023ffd7310f472ee9d106c78ee7acbb9f20d1bc0.

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Case 1:26-cr-10030-RGS Document 49 _ Filed 03/27/26 Page1of2

UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS

UNITES STATES OF AMERICA

Criminal Case #26-10030-RGS-JCB

ROSALIE CLEMENT-JACKSON

MOTION TO MODIFY CONDITIONS OF BOND

Defendant Clement-Jackson herein respectfully moves this Honorable Court for a
modification of her conditions of bond, ordered by U.S.D.C., Southern District of
Florida; specifically, condition #2, that she “[m]ay not travel outside the Southern
District of Florida unless otherwise approved by the Court prior to such travel.” Ordered
by Magistrate Judge Panayotta on 02/09/2026, Criminal Docket #0:26-mj-06063-PAB.
Defendant proposes the conditions of bond allow for the defendant to travel via

automobile with her son and family from her resident to Tallahassee, Florida.

As reasons therefor, Defendant states that she has need to travel with her son on a
college visit to Florida A&M University (FAMU) in Tallahassee, FL, from April 3rd to
April 4", 2026. Defendant and her family plan to depart on Thursday, April 2nd, at
approximately 6:00 PM; and, then, depart Tallahassee for their return trip on April 4th at
11:00 AM. The drive is expected to take approximately eight hours.

In support of this motion, Defendant further represents that AUSA Kristen

Kearney and Probation Officer Mackenzie Hilaire express “no objection” to the motion.

One Boston Place
201 Washington Street, Suite 2600, Boston, MA 02108
Phone (617) 441-0444 — Fax (617) 380-4440
Email: AttorneyPerez@Gmail.com

Date: March 27, 2026
Case 1:26-cr-10030-RGS Document 49 _ Filed 03/27/26 Page 2 of 2

CERTIFICATE OF SERVICE

I, Lorenzo Perez, attorney for the Defendant, hereby certify that on this s day Fseryed
via email a copy of the Defendant's Motion to Modify Conditions of Bond up@gn the

prosecutor(s) and interested parties in this matter.
Grams Perez

Date: March 27, 2026

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