Consent Motion to Modify Release Conditions — United States v. David Epstein (Dkt. 26)

Summary

A Motion to Modify Release Conditions (Consent) filed November 15, 2024 in United States of America v. David Epstein, Cr. No. RDB-23-210, in the United States District Court for the District of Maryland (Document 26). Defendant David Epstein, through counsel, asks the court to permit the opening of personal checking and savings accounts, with monitoring by Pretrial Services. The motion states that a condition of release was that Epstein could "not open any bank accounts or lines of credit," and that on November 13, 2024, Capital One Bank notified him that it was closing his personal checking and savings accounts. It states that Epstein pled guilty to count three on October 8, 2024 and that United States Probation Officer Erin Thumma and Assistant United States Attorney Paul Riley consent to the motion.

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    Case 1:23-cr-00210-RDB           Document 26          Filed 11/15/24    Page 1 of 2



                        UNITED STATES DISTRICT COURT
                        FOR THE DISTRICT OF MARYLAND


UNITED STATES OF AMERICA                     *

     V.                                      *                        Cr. No. RDB-23-210
DAVID EPSTEIN                                *

                Defendant                    *

For: DAVID EPSTEIN                       *

                  MOTION TO MODIFY RELEASE CONDITIONS
                              (CONSENT)

    Defendant, DAVID EPSTEIN, by his undersigned counsel, hereby requests this

Honorable Court to modify his release conditions to permit him to open personal

checking and savings accounts, with monitoring by Pretrial Services, and as grounds

states:

    1.    Mr. Epstein was indicted on June 14, 2023, on charges of wire fraud related to a

          Paycheck Protection Program loan.      He had his initial appearance by agreement

          on August 3, 2023.    He was released on conditions the same day and has been

          on release without incident for over a year.

    2.    Epstein pled guilty to count three on October 8, 2024 and is scheduled for

          sentencing on January 14, 2025.

    3.    One of the conditions of release was that he could “not open any bank accounts

          or lines of credit.” ECF 10, para. 8(w).

    4.    On November 13, 2024, Epstein was notified by Capital One Bank that the bank

          was closing his personal checking and savings accounts.      The bank provided no

          advance notice or grounds for its actions.     The Capital One accounts were

          Epstein’s only personal bank accounts.
   Case 1:23-cr-00210-RDB             Document 26       Filed 11/15/24     Page 2 of 2



    5.   Mr. Epstein, like most people, needs bank accounts to receive his paycheck and

         then pay his bills. Without any bank accounts, he cannot pay his mortgage,

         electric or water bills, buy food for his family or pay other normal debts incurred

         as part of a regular life.

    6.   He therefore seeks Court approval to open personal checking and savings

         accounts.    He agrees that Pretrial Seervices can access these accounts if they so

         desire.

    7.   United States Probation Officer Erin Thumma states that she consents to the

         granting of this motion

    8.   Assistant United States Attorney Paul Riley states that he consents to the

         granting of this motion.

         WHEREFORE, DAVID EPSTEIN, hereby requests this Honorable Court to

    permit him to open personal checking and savings accounts, with monitoring by

    Pretrial Services.

                                      Respectfully submitted,

                                        _______/s/__________________
                                        Richard Bardos, Of Counsel
                                        Schulman, Hershfield & Gilden, P.A.
                                        1 East Pratt Street, 9th Floor
                                        Baltimore, Maryland 21202
                                        (410) 332 0850


                              CERTIFICATE OF SERVICE

    I HEREBY CERTIFY that on this 15th of November, 2024, a copy of the foregoing
was served electronically by ECF to: Office of the United States Attorney, 36 South
Charles Street, Fourth Floor, Baltimore, Maryland 21201 and all defense counsel.

                                 _____/s/______________________
                                 Richard Bardos


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