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Consent Motion to Modify Conditions of Release — United States v. Tomeka Glenn (District of Maryland, 08/18/23)

Summary

A Consent Motion to Modify Conditions of Release filed 08/18/23 as Document 34 in United States v. Tomeka Glenn, Criminal Case No. RDB-23-0027 (D. Md.), made with the consent of all parties. It asks the Court to remove the electronic home monitoring restriction that was originally imposed, in lieu of a 9:00pm to 8:30am curfew and submission to GPS location monitoring. The motion states that the concerns behind the more onerous restriction have been tempered and allayed by Ms. Glenn's total compliance with the conditions of release for the past seven months. It states that Assistant United States Attorney Paul Riley and United States Probation Officer Vicky Adams were consulted and that neither party objects.

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“Consent Motion to Modify Conditions of Release — United States v. Tomeka Glenn (District of Maryland, 08/18/23).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-mdd-529189-34-0-be283414da/, SHA-256 be48bb6763cca89091241c34bee5466b578ae03337bdf4fd270e3e449ebc3087.

Full text

     Case 1:23-cr-00027-RDB             Document 34     Filed 08/18/23          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 his

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

ordered in Ms. Glenn’s pending matter, with the consent of all parties, 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 not allowed to leave her home unless authorized to do so.

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

                     electronic home monitoring restriction that was originally imposed as a

                     condition of her release in lieu of a 9:00pm to 8:30am curfew and

                     submission to GPS location monitoring. She respectfully submits that



                                            −1−
    Case 1:23-cr-00027-RDB         Document 34        Filed 08/18/23       Page 2 of 2


                  the concerns originally held in support of this more onerous restriction

                  have been tempered and allayed by Ms. Glenn’s total compliance with

                  her conditions of release for the past seven months.

       4.         Undersigned counsel has spoken with both Assistant United States

                  Attorney Paul Riley and United States Probation Officer Vicky Adams

                  about this request. Neither party objects to this request.

       WHEREFORE, Ms. Glenn respectfully requests that the Court grant this motion and

       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 18, 2023, a copy of Defendant's Consent 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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