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Consent Motion to Modify Conditions of Release — United States v. Tomeka Glenn (District of Maryland, 11/19/23)

Summary

Document 41, filed 11/19/23 in United States v. Tomeka Glenn, Criminal Case No. RDB-23-0027 (D. Md.), is a Consent Motion to Modify Conditions of Release made by Ms. Glenn through attorney Christopher C. Nieto. It states that on August 18, 2023 supervision was adjusted to a curfew of 9:00pm to 8:30am in lieu of electronic home monitoring. With the Thanksgiving holiday that week, the motion asks the Court for permission to extend the curfew until 11:00pm on Thursday night only, so that Ms. Glenn can visit family members. 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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Cite this document

“Consent Motion to Modify Conditions of Release — United States v. Tomeka Glenn (District of Maryland, 11/19/23).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-mdd-529189-41-0-35af755e01/, SHA-256 64d7b35e79105dcd978db02266f8ce8e2596a53bcee7e351144078d8bdd1869e.

Full text

     Case 1:23-cr-00027-RDB            Document 41      Filed 11/19/23        Page 1 of 3


                     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.          On August 18, 2023, after seven months of compliance with her pre-trial

                     release conditions, Ms. Glenn’s supervision was adjusted to allow her to

                     submit to a curfew of 9:00pm to 8:30am in lieu of electronic home

                     monitoring. Her adjustment to this new level of supervision has been

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

                     complied with all the conditions of her release.




                                            −1−
    Case 1:23-cr-00027-RDB          Document 41        Filed 11/19/23      Page 2 of 3


       3.          With the Thanksgiving holiday this week, Ms. Glenn respectfully

                   requests permission of the Court to extend her curfew until 11:00pm on

                   Thursday night only. She plans to visit various family members for the

                   holiday and, based on travel time and her desire to spend as much time

                   with them as she can, she anticipates requiring an extra two hours outside

                   her home for the holiday.

       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 November 19, 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/_________________


                                           −2−
Case 1:23-cr-00027-RDB   Document 41    Filed 11/19/23    Page 3 of 3


                               Christopher C. Nieto, #30031
                               Attorney for Ms. Glenn




                             −3−

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