Consent Motion to Modify Curfew — United States v. Kevin Davis (District of Maryland, 12/18/23)

Summary

A Consent Motion to Modify Curfew filed 12/18/23 as Document 49 in United States v. Kevin Davis, Case No. RDB-23-27 (D. Md.), by Davis through attorney C. Justin Brown. It asks the Court to move Davis's curfew from 9:00 P.M. back until 11:00 P.M. on December 25, so that Davis can attend a family Christmas dinner that begins at 8:00 P.M., and states that all other terms of pretrial release would remain the same. It states that Davis's Pretrial Services Officer consents and that Assistant U.S. Attorney Paul Riley has no objection.

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Full text

       Case 1:23-cr-00027-RDB            Document 49       Filed 12/18/23       Page 1 of 2



                     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 CURFEW

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

requests that this Honorable Court temporarily modify his curfew for the Christmas

holiday. In support of this Motion, Davis states the following:

       1. On December 25, 2023, Davis wishes to attend his family’s Christmas dinner,

            which begins at 8:00 P.M.

       2. Davis’s curfew requires him to be home by 9:00 P.M.

       3. Davis requests that his curfew time be pushed back until 11:00 P.M. on

            December 25 so that he may attend his family’s Christmas dinner.

       4. Other than changing Davis’s curfew to 11:00 P.M. on December 25, all other

            terms of pretrial release would remain the same.

       5. Undersigned counsel has spoken with Davis’s Pretrial Services Officer,

            Nicholas Luko, and he consents to this request. Assistant U.S. Attorney Paul

            Riley also has no objection to this request.

       WHEREFORE, Defendant Kevin Davis respectfully requests that this Court grant

his motion and modify his curfew to 11:00 P.M. on December 25, 2023.
      Case 1:23-cr-00027-RDB      Document 49      Filed 12/18/23   Page 2 of 2




                                       Respectfully Submitted,


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




                           CERTIFICATE OF SERVICE

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

all parties via CM/ECF.

                                       _________/s/__________
                                       C. Justin Brown




                                          2


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