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Consent Motion to Modify Conditions of Release — United States v. Tomeka Glenn (District of Maryland, 07/05/23)

Summary

A Consent Motion to Modify Conditions of Release filed 07/05/23 as Document 30 in United States v. Tomeka Glenn, Criminal Case No. RDB-23-0027 (D. Md.), by Ms. Glenn through attorney Christopher C. Nieto. It states that Ms. Glenn's uncle passed away in late June, and asks the Court to modify the conditions of release for the limited purpose of attending the funeral, burial and repast on July 7, 2023. It states that one condition is electronic home monitoring with no leaving the residence without prior Court approval, and that for the past six months Ms. Glenn has had no issues with the supervising officer. Counsel states that Assistant United States Attorney Paul Riley and United States Probation Officer Vicky Adams do not object, and asks the Court to enter the attached Amended Order.

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Cite this document

“Consent Motion to Modify Conditions of Release — United States v. Tomeka Glenn (District of Maryland, 07/05/23).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-mdd-529189-30-0-e8b8c23e4c/, SHA-256 207512fd13ce27c3231ae4d07261304b614769c71f9a37fd4e11b561ce455b87.

Full text

     Case 1:23-cr-00027-RDB            Document 30        Filed 07/05/23       Page 1 of 2


                    IN THE UNITED STATES DISTRICT COURT
                       FOR THE DISTRICT OF MARYLAND

UNITED STATES OF AMERICA                       *

v.                                             * Criminal Case No. RDB-23-0027

TOMEKA GLENN                                   *

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

          CONSENT MOTION TO MODIFY CONDITIONS OF RELEASE

         Now comes the defendant, Tomeka Glenn ("Ms. Glenn"), by and through her

attorney, Christopher C. Nieto, and moves this Court to modify the conditions of release

ordered in Ms. Glenn’s pending matter, and in support thereof states as follows:

1.          On January 6, 2023, Ms. Glenn appeared in federal court for her initial

            appearance. The Government was not seeking detention, and conditions of

            release were fashioned. One of the conditions specifically imposed on Ms.

            Glenn was that she was subject to electronic home monitoring and is not allowed

            to leave her residence without prior Court approval.

2.          For the past six months, Ms. Glenn’s adjustment to supervision has been

            satisfactory: she has had no issues with her supervising officer and has complied

            with all the conditions of her release.

3.          Sadly, Ms. Glenn’s uncle passed away in late June. The family is having the

            funeral on July 7, 2023 at 11am at March Funeral Home at 1101 E. North

            Avenue, Baltimore, MD 21202 and the burial thereafter at King Memorial Park

            at 8710 Dogwood Road, Baltimore, MD 21244. The family also intends to have

            a funeral repast at the conclusion of the burial at the funeral home.



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     Case 1:23-cr-00027-RDB         Document 30       Filed 07/05/23      Page 2 of 2


4.          Ms. Glenn would like to attend this funeral, burial, and repast, but her release

            conditions prevent her from attending without the Court’s intervention.

            Consequently, Ms. Glenn respectfully requests that the Court modify the

            conditions of her release for the limited purpose of allowing her to attend this

            funeral and grieve with her family. Undersigned counsel has spoken with both

            Assistant United States Attorney Paul Riley and United States Probation Officer

            Vicky Adams about this request, and neither object.

       WHEREFORE, Ms. Glenn respectfully requests that the Court enter the attached

Amended Order.



                                     Respectfully submitted,

                                        /s/___________________

                                     CHRISTOPHER C. NIETO, #30031
                                     Nieto Law Office
                                     1 North Charles Street, Suite 1301
                                     Baltimore, Maryland 21201
                                     Phone: (443) 863-8189
                                     Fax: (443) 378-5723
                                     Email: cnieto@nietolawoffice.com




                             CERTIFICATE OF SERVICE

       I hereby certify that on July 5, 2023, a copy of Defendant's Motion to Modify, which

was electronically filed in this case, was emailed to Paul Riley and Vicky Adams.

                                                /s/_________________
                                             Christopher C. Nieto, #30031
                                             Attorney for Ms. Glenn



                                           −2−

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