Motion to Amend Order Setting Conditions of Release (Consent) — United States v. David Epstein

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A Motion to Amend the Order Setting Conditions of Release (Consent) filed September 13, 2023 by Defendant David Epstein, through counsel, in United States of America v. David Epstein, No. 23-cr-00210-RDB, in the United States District Court for the District of Maryland. The motion states that by Order of August 3, 2023, Epstein is not to enter into any financial transactions exceeding $2,000 without prior approval from Pretrial Services, with the exception of mortgage payments, legal fees and litigation costs. It asks permission to borrow an amount not exceeding $10,000 to supplement insurance proceeds toward a replacement vehicle or, alternatively, to lease a vehicle. It states that Paul Riley, Assistant U.S. Attorney and Ken Langston of Pretrial Services have agreed to the alternate requests.

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Case 1:23-cr-00210-RDB Document14 _ Filed 09/13/23. Page1of2

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MARYLAND

UNITED STATES OF AMERICA, *
Plaintiff, *
Criminal No. 8:23-cr-00210-RDB
Vv. *
DAVID EPSTEIN *
Defendant.
* * * * * * * * * * * * * *

MOTION TO AMEND THE ORDER SETTING CONDITIONS OF RELEASE
(CONSENT)

Defendant David Epstein (“Epstein”) by and through undersigned counsel hereby requests
permission of this Court to Amend the Order Setting Conditions of Release, and in support states:

1. By Order of this Court on August 3, 2023, Epstein is not to enter into any financial
transactions exceeding $2,000 without prior approval from Pretrial Services, with the exception of
mortgage payments, legal fees and litigation costs. ECF 10.

2. During one of the recent storms, a tree fell on Mr. Epstein’s vehicle and caused
sufficient damage to the vehicle that the insurance company deemed the vehicle a total loss (see
Exhibit 1).

3. As aresult of the damage, Epstein is forced to either purchase or lease a replacement
vehicle. To replace the vehicle, a purchase would require Epstein to borrow a maximum of $10,000
to supplement the amount of money the insurance company has agreed to pay for the damage to
the vehicle. Therefore, Epstein is hereby requesting permission to amend the Order Setting
Conditions of Release to allow Epstein, if necessary, to borrow an amount not exceeding $10,000,
to supplement the insurance proceeds in connection with the purchase of a replacement vehicle or,

in the alterative, authorizing Epstein to lease a vehicle.
Case 1:23-cr-00210-RDB Document14 _ Filed 09/13/23 Page 2of2

4. Both Paul Riley, Assistant U.S. Attorney and Ken Langston of Pretrial Services
have agreed to Epstein’s alternate requests (Exhibit 2).

WHEREFORE, Defendant David Epstein requests approval of this Court to amend the
ORDER SETTING CONDITIONS of RELEASE to allow Epstein, if necessary, to borrow an
amount, not exceeding $10,000, to supplement the insurance proceeds in connection with the
purchase of a replacement vehicle or in the alterative authorizing Epstein to lease a vehicle.
Dated: September 13, 2023 Respectfully submitted,

/s/ Robert B. Schulman, Esq.

Robert B. Schulman, Fed. Bar No. 00068

Richard Bardos, Fed Bar No. 01559
rbardos@shg-legal.com

Schulman, Hershfield & Gilden, P.A.
One East Pratt Street, Suite 904
Baltimore, Maryland 21202

Tel: (410) 332-0850

Fax: (410) 332-0866

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 13" day of September, 2023, the foregoing Pretrial

Motion was filed and served, using the ECF filing system, upon:
Paul Riley, Esquire
Assistant United States Attorney

36 S. Charles Street
Baltimore, MD 20201

/s/ Robert B. Schulman, Esq.


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