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Motion to Modify Conditions of Release — United States v. German Olivo (District of Massachusetts, Document 61)

Summary

A Motion to Modify Conditions of Release, Document 61, filed April 16, 2026 in United States of America v. German Olivo, Criminal No. 26-10030-RGS, in the United States District Court for the District of Massachusetts. Counsel for the defendant asks the court to permit travel to and presence in Nashville, Tennessee from April 24, 2026 through April 27, 2026, to participate in a 5K road race. The motion states that the defendant is released on conditions in the Southern District of Florida, that Probation assents and that the government takes no position. A footnote states that itinerary information will be provided to Probation in advance. The motion is signed /s/ by attorney Ian Gold.

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“Motion to Modify Conditions of Release — United States v. German Olivo (District of Massachusetts, Document 61).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-mad-295477-61-0-779eff054a/, SHA-256 13d3e2f905d0c4372cbadd5d22217909a001852fcf5371a4599c5e77965dfe08.

Full text

        Case 1:26-cr-10030-RGS            Document 61         Filed 04/16/26      Page 1 of 2




                             UNITED STATES DISTRICT COURT
                          FOR THE DISTRICT OF MASSACHUSETTS


UNITED STATES OF AMERICA, ​ ​                   ​       )
​    ​     ​    ​     ​     ​                   ​       )​      ​    ​    ​      ​     ​
v.​  ​     ​    ​     ​     ​                   ​       )​      CRIMINAL NO. 26-10030-RGS
​    ​     ​    ​     ​     ​                   ​       )
GERMAN OLIVO,​ ​      ​     ​                   ​       )​
​      ​   ​    Defendant.​ ​                   ​       )



                    MOTION TO MODIFY CONDITIONS OF RELEASE


        NOW COMES counsel for the Defendant, German Olivo, and moves to modify the

conditions of his release to permit him to travel to and be in Nashville, Tennessee, between the

dates of April 24, 2026, to and including April 27, 2026, in order to participate in a 5K road race

which is part of the Rock ‘n’ Roll running series.

        Mr. Olivo is a personal trainer employed by Sweat440. He is released on conditions in

the Southern District of Florida. His participation in this event, which was planned and paid for

prior to arrest in this case, is in connection with his professional activities as a trainer. He is

traveling and participating in the event as part of a group of personal trainer peers and clients.

        Mr. Olivo’s participation in this event is part of a planned program of race participation

that Mr. Olivo expects will permit him to obtain professional certifications and advance his

career as a personal trainer.

        Undersigned counsel has consulted with Probation in both the District of Massachusetts

and the Southern District of Florida. Probation assents to this request.

        The government takes no position on this request.
       Case 1:26-cr-10030-RGS           Document 61         Filed 04/16/26     Page 2 of 2




       WHEREFORE, Mr. Olivo requests the Court temporarily modify his conditions of

release to permit him to be in and travel to and from Nashville, TN, between April 24, 2026, and

April 27, 2026.1

                                                     Respectfully submitted,

                                                     GERMAN OLIVO,
                                                     By his attorney,

                                                     /s/Ian Gold

                                                     Ian Gold (BBO #665948)
                                                     185 Devonshire Street, Suite 302
                                                     Boston, MA 02110
                                                     (617) 297-7686 (office & mobile)
                                                     ian.gold@iangoldlaw.com



April 16, 2026


                                 CERTIFICATE OF SERVICE

​         I hereby certify that this document(s) filed through the ECF system will be sent
electronically to the registered participants as identified on the Notice of Electronic Filing (NEF)
on this date, Apr. 16, 2026.
​       ​        ​       ​        ​      ​      ​        /s/ Ian Gold




1
 Itinerary information will be provided to Probation in advance. Defendant also requests
Probation be granted to authority to extend this authorization as appropriate in the event of
weather-related flight delays.
                                                 2

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