Motion to Modify Conditions of Release — United States v. Tomeka Glenn (District of Maryland, January 30, 2024)

Summary

A Motion to Modify Conditions of Release filed January 30, 2024 in United States v. Tomeka Glenn, Criminal Case No. RDB-23-0027, in the United States District Court for the District of Maryland (Document 57). The motion, brought by defendant Tomeka Glenn through attorney Christopher C. Nieto, asks the court to remove the curfew restriction imposed as a condition of release. It states that on August 18, 2023, supervision was adjusted to a curfew of 9:00pm to 8:30am, and that a hearing on modification was conducted before the Honorable J. Mark Coulson. It states that Government counsel objects to the request and asks, in the alternative, for a hearing before Magistrate Judge Coulson. A proposed order is attached.

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Cite this document

“Motion to Modify Conditions of Release — United States v. Tomeka Glenn (District of Maryland, January 30, 2024).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-mdd-529189-57-0-a3750367a7/, SHA-256 e1cd408b3b0e77dbc6bd99a8e759c6874a0f56b7d6ff50953ddbda5a5131c9fe.

Full text

Case 1:23-cr-00027-RDB Document 57 Filed 01/30/24 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 *

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

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, 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 was satisfactory: she had no issues with her supervising officer and

complied with all the conditions of her release.

3. After eleven months of compliance with her pre-trial release conditions,

Ms. Glenn sought a hearing to modify the conditions of release and remove the curfew

restriction. The hearing was conducted before the Honorable J. Mark Coulson on December

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Case 1:23-cr-00027-RDB Document 57 Filed 01/30/24 Page 2 of 3

7, 2023, during which time United States Pre-Trial Services Officer Vicky Adams, who

supervises Ms. Glenn, agreed with this request. Government counsel, however,

opposed this modest modification.

4. At the conclusion of the hearing, Judge Coulson modified the curfew but

declined to remove that condition of release entirely. However, the Court indicated to the

parties that if Ms. Glenn could show continued compliance with this lessened restriction,

His Honor would consider removing this condition entirely. Additionally, His Honor

instructed counsel to file this motion with his chambers directly as he was well-versed in

the arguments from the parties and the history of this pre-trial release.

5. In the past near two months, as well as the aggregate almost thirteen (13)

months since her initial arrest, Ms. Glenn has continued to be compliant with the conditions

of her release. Undersigned counsel spoke with USPO Adams, who stated that she has no

objection to this request; she confirmed that Ms. Glenn has remained in compliance and

indicated that location monitoring would not mitigate any risks associated with the case at

this point.

6. Undersigned counsel spoke with AUSA Riley regarding this request, and

he blanketly objected, indicating that no further loosening of the conditions of release is

appropriate.

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

curfew restriction that was imposed as a condition of her release. We respectfully submit

that the concerns originally held in support of this restriction have been tempered and

allayed by Ms. Glenn’s total compliance with all her conditions of release throughout the

pendency of this case. A proposed order is attached to this filing.

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Case 1:23-cr-00027-RDB Document 57 Filed 01/30/24 Page 3 of 3

8. In the alternative, since the Government continues to oppose this request,

Ms. Glenn would respectfully request a hearing for the Court to rule on this motion. In

anticipation of this hearing, undersigned counsel contacted Magistrate Judge Coulson’s

chambers, who is available on February 8, 2024 at 1:00pm, but the Government has not

indicated if this date/time is acceptable for their schedule.

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

in the alternative, schedule a hearing before Magistrate Judge Coulson at a mutually

agreeable time.

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 January 30, 2024, 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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