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Consent Motion to Modify Conditions of Release — United States v. Kevin Davis (District of Maryland, 04/18/23)

Summary

A Consent Motion to Modify Conditions of Release filed 04/18/23 as Document 27 in United States v. Kevin Davis, Case 1:23-cr-00027-RDB (D. Md.), by Davis through attorney C. Justin Brown. It asks the Court to permit Davis to attend a pre-prom sendoff for Davis's daughter on April 22, 2023, from 5pm-7pm, with an additional 30 minutes before and after for travel time. It states that the January 6, 2023 order placed Davis on pretrial release on personal recognizance, and that the condition at issue bars leaving the residence except for employment, medical necessities, attorney visits, court appearances, or other approved activities. It states that Pre-Trial Officer Nick Luoco and Assistant United States Attorney Paul Riley do not object.

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Cite this document

“Consent Motion to Modify Conditions of Release — United States v. Kevin Davis (District of Maryland, 04/18/23).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-mdd-529189-27-0-2b683fb676/, SHA-256 9033c6dce8475d10e51bb447f39be287bc995eef1ca8b8029977d2b3946ea57a.

Full text

       Case 1:23-cr-00027-RDB           Document 27    Filed 04/18/23       Page 1 of 3



                     IN THE UNITED STATES DISTRICT COURT
                        FOR THE DISTRICT OF MARYLAND

UNITED STATES OF AMERICA                    *

           v.                               *     Case No.: RDB-23-27

KEVIN DAVIS                                 *

*      *        *     *      *      *       *     *      *      *       *       *         *

            CONSENT MOTION TO MODIFY CONDITIONS OF RELEASE

       Kevin Davis, through his attorney, C. Justin Brown, Brown Law, respectfully

moves this Court to modify the terms of his release to permit Davis to attend his

daughter’s pre-prom sendoff on April 22, 2023. In support of his request, Davis states as

follows:

       1.       On January 6, 2023, this Court ordered Davis’s pretrial release on his

personal recognizance.

       2.       Davis now seeks a modification of this Court’s order, specifically

Condition Number 8(s), which prohibits him from leaving his residence except for

employment, medical necessities, attorney visits, court appearances, or other activities

approved by the Court or pretrial services. Davis requests that this provision be modified

to allow him to travel to Randallstown, Maryland, to attend his daughter’s pre-prom

sendoff.

       3.       The sendoff will take place on April 22, 2023, from 5pm-7pm. It will be

held at Khadine Maragh’s house at 9127 Sunset Ridge Road in Randallstown, Maryland.

Maragh is the mother of Davis’s daughter, Azoria Davis. Maragh and Davis have shared
       Case 1:23-cr-00027-RDB         Document 27      Filed 04/18/23      Page 2 of 3



custody of Azoria.

       4.     Azoria is 17 years old and a senior at Windsor Mill Academy. Prom is a

pivotal event in any teenage girl’s life and Davis, being an involved father, wants to be

there to support his daughter. The purpose of the event is to take pictures and celebrate

this momentous occasion in Azoria’s life.

       5.     Davis respectfully moves this Court to modify the terms of his release to

permit him to attend this event from 5pm-7pm, with an additional 30 minutes before and

after the event to allow for travel time.

       6.     Tamika Glenn, Davis’s codefendant in this case, will not be in attendance.

       7.     Davis’s Pre-Trial Officer, Nick Luoco, does not object to this request.

       8.     Assistant United States Attorney Paul Riley does not object to this request.

       WHEREFORE, for the reasons set forth above, Davis respectfully requests that

this Court modify the conditions of his pretrial release to permit him to attend his

daughter’s pre-prom sendoff on April 22, 2023, subject to monitoring by U.S. Pretrial

and Probation Services.


                                            Respectfully Submitted,



                                            _________/s/__________
                                            C. Justin Brown
                                            BROWN LAW
                                            1 N. Charles St., Suite 1301
                                            Baltimore, Maryland 21201
                                            Tel: 410-244-5444
                                            Fax: 410-934-3208
                                            brown@cjbrownlaw.com

                                              2
      Case 1:23-cr-00027-RDB       Document 27       Filed 04/18/23    Page 3 of 3



                           CERTIFICATE OF SERVICE

      I hereby certify that on April 18, 2023, a copy of this Motion was served on all

parties via CM/ECF.

                                         _________/s/__________
                                         C. Justin Brown




                                            3

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