Motion to Amend Conditions of Supervised Release (Consent) — United States v. David Epstein (Document 53)
Summary
Consent motion in United States v. David Epstein, Cr. No. RDB-23-210, in the District of Maryland. Defendant David Epstein states that on May 7, 2025, the Court sentenced him to one year and one day followed by twelve months of home confinement (ECF 45). He asks the Court to permit religious services in excess of Probation's policy, which he says allows a maximum of 4 hours a week including travel, and employment outside the home beyond a maximum of 50 hours a week. He also asks to take his daughter to tournaments from June 28 to July 29, 2026, with a travel schedule given to Probation in advance. The motion states that Probation Officer Vicki Adams and Assistant United States Attorney Ariel Evans consent.
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“Motion to Amend Conditions of Supervised Release (Consent) — United States v. David Epstein (Document 53).”
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Case 1:23-cr-00210-RDB Document 53 Filed 06/15/26 Page 1 of 4
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 AMEND CONDITIONS OF SUPERVISED RELEASE
(CONSENT)
Defendant, David Epstein, though his undersigned counsel, hereby submits this
motion to amend his conditions on supervised release and as grounds states:
1. On May 7, 2025, this Court sentenced Mr. Epstein to a period of
incarceration of one year and one day, followed by twelve months of home
confinement. ECF 45. At that time, the Court permitted the defendant to
self-surrender to his sentence on August 7, 2025. Id.
2. Subsequently, the Court agreed to extend the self-surrender date to October
16, 2025, when Mr. Epstein surrendered to his designated facility, Otisville,
New York.
3. The Bureau of Prison released Epstein to a half way house in April, 2026.
He was then placed on supervised release in late May, 2026.
4. While he was incarcerated at Otisville, Mr. Epstein began practicing as an
Orthodox Jew, and he continues that practice on release. That practice
includes going to synagogue twice a day during the week for
Case 1:23-cr-00210-RDB Document 53 Filed 06/15/26 Page 2 of 4
approximately an hour each time, plus going to synagogue on Saturdays for
three to four hours, totaling, without travel, about 16 hours a week.
5. Although the Court, in setting his conditions of supervised release at the
time of sentencing allowed him out for religious services, ECF 45, p. 4,
Probation advises that their policy is to allow only a maximum of 4 hours a
week for religious services, which includes travel.
6. In order for his Probation Officer to permit him to attend his religious
services as required, Probation advises that an Order from the Court
exception Mr. Epstein from the 4 hours limit would be needed.
7. The defendant respectfully requests that this Court issue an Order
permitting him to attend his religious services as needed, in excess of
Probation’s policy, with a schedule to be provided to his Probation Officer
each week in advance.
8. Second, at sentencing, the Court permitted the defendant to leave his home
for employment., ECF 45, id. Probation advises that their policy is to
allow only a maximum of 50 hours a week for a defendant to be out of his
house for any reason. Mr. Epstein intends to seek full time employment,
40 hours a week. This employment, added to his religious outings, would
exceed Probation’s 50 hour maximum.
9. The defendant respectfully requests that this Court issue an Order
permitting him to obtain employment and be out of his home, in excess of
Case 1:23-cr-00210-RDB Document 53 Filed 06/15/26 Page 3 of 4
Probation’s policy, with a schedule to be provided to his Probation Officer
each week in advance.
10. Finally, as the Court may recall, Mr. Epstein’s 16 year old daughter plays
softball and has now qualified for a travel team. From June 28 to July 29,
2026, she has tournaments in Colorado, Ohio, North Carolina and
Tennessee. The tournaments are 3-4 days. The Crush National Summer
Tournament schedule is attached as Exhibits 1 and 2.
11. He would like to be able to take his daughter to these events. His current
supervised release conditions prohibit him from leaving Maryland. His
daughter cannot drive herself to these games and the defendant’s wife is
recovering from surgery and cannot travel long distances.
12. As a result, the defendant respectfully requests to be permitted to take his
daughter to these tournaments, with a travel schedule provided to Probation
in advance.
13. Probation Officer Vicki Adams advised that she consents to the granting of
this motion
14. Assistant United States Attorney Ariel Evans also advises that his consents
to the granting of this motion.
WHEREFORE, defendant David Epstein respectfully requests that this Court
amend his conditions on supervised release as outlined herein.
Respectfully submitted,
_______/s/__________________
Richard Bardos, Of Counsel
Case 1:23-cr-00210-RDB Document 53 Filed 06/15/26 Page 4 of 4
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 June, 2026, 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.
_____/s/______________________
Richard Bardos
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