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Consent Motion to Modify Conditions of Release — United States v. Tomeka Glenn (District of Maryland, 08/02/23)

Summary

Document 32, filed 08/02/23 in United States v. Tomeka Glenn, Criminal Case No. RDB-23-0027 (D. Md.), is a Consent Motion to Modify Conditions of Release brought by Ms. Glenn through attorney Christopher C. Nieto. It states that a friend passed away in late July and that the wake and funeral are on August 5, 2023, with a funeral repast from 3-6pm. The motion asks the Court to modify the conditions of release for the limited purpose of attending the funeral, burial and repast. It states that for the past seven months Ms. Glenn has had no issues with the supervising officer, and that Assistant United States Attorney Paul Riley and United States Probation Officer Vicky Adams do not object.

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Cite this document

“Consent Motion to Modify Conditions of Release — United States v. Tomeka Glenn (District of Maryland, 08/02/23).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-mdd-529189-32-0-5729508489/, SHA-256 9adfe6c9ffbe4e1c32a7ce0952edde2e0639b81e1450b801ed32f17a9a294225.

Full text

     Case 1:23-cr-00027-RDB            Document 32        Filed 08/02/23       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 seven 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 friend passed away in late July. The family is having the

            wake and funeral on August 5, 2023, starting at 10am at March Life Tribute

            Center, 5616 Old Court Road, Windsor Mill. The family also intends to have a

            funeral repast at the conclusion of the burial at a reception hall from 3-6pm.




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     Case 1:23-cr-00027-RDB        Document 32       Filed 08/02/23      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 August 2, 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



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