Motion for Bond Review — No. 8:23-cr-00347 (Dkt. 56, D. Md.)

Summary

A Motion for Bond Review, Document 56 filed December 23, 2024 in the District of Maryland (Case 8:23-cr-00347-LKG-1), United States v. Renard Rasheed Brown, filed by defense counsel Douglas J. Wood of Roberts and Wood. The defendant is charged with one count of possession of a firearm and ammunition after a felony conviction under 18 U.S.C. § 922(g)(1), arising from a March 6, 2023 arrest in which a firearm was found in his vehicle. The motion notes that the predicate offense occurred in 2003, over twenty years earlier, and that he has substantial ties to the community as a father and grandfather and a skilled carpenter. It asks the court to review the conditions of release and impose reasonable conditions.

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           Case 8:23-cr-00347-LKG      Document 56         Filed 12/23/24     Page 1 of 3



 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND
UNITED STATES OF AMERICA,                    :
                                             :

v.                                           :          Case No.: 8:23-cr-00347-LKG-1
                                             :
RENARD RASHEED BROWN                         :
                                             :
       Defendant.                            :
                               MOTION FOR BOND REVIEW

       The Defendant, by and through undersigned counsel, respectfully moves this Honorable

Court to review the conditions of release in the above-captioned matter. In support of this Motion,

the Defendant states as follows:

       1.       The Defendant is charged with one count of possession of a firearm and

ammunition after having been convicted of a crime punishable by imprisonment for a term

exceeding one year, in violation of 18 U.S.C. § 922(g)(1).

       2.       The Defendant was arrested for this offense on March 6, 2023, by members of the

Prince George’s County Police Department. At the time of his arrest, the firearm was found in his

vehicle. Other than the alleged possession of the firearm, no additional criminal conduct has been

alleged.

       3.       Following his arrest, the Defendant was charged in the District Court of Maryland

for Prince George’s County. These charges were subsequently dismissed after the Defendant was

indicted in this Court in the above-captioned matter.

       4.       The predicate offense underlying the current federal charge occurred over twenty

years ago, in 2003.




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        Case 8:23-cr-00347-LKG            Document 56      Filed 12/23/24      Page 2 of 3



        5.      Upon information and belief, the Defendant has not been convicted of any serious

offenses in the intervening years.

        6.      The Defendant has not yet been able to resolve this case and respectfully requests

that he be released pending resolution.

        7.      The Defendant has substantial ties to the community. He is a father and grandfather,

with children and grandchildren residing in the area who rely on his presence and support.

        8.      The Defendant is a skilled carpenter with extensive experience and has been

gainfully employed in the construction industry for many years.

        9.      Upon release, the Defendant is able to reside with his family and is expected to

return to gainful employment in the community.

        10.     The Defendant respectfully requests that this Court impose reasonable conditions

of release to ensure his appearance at all proceedings while allowing him to return to the

community.

        WHEREFORE, the Defendant respectfully requests that this Honorable Court review the

conditions of release and impose reasonable conditions to facilitate his release pending the

resolution of this case.

                                              Respectfully submitted,
                                              ROBERTS AND WOOD

                                                /s/ Douglas J. Wood
                                              Douglas J. Wood
                                              Bar ID No. 04248
                                              Attorney for Defendant
                                              6801 Kenilworth Avenue, Suite 202
                                              Riverdale, Maryland 20737
                                              (301) 699-0764
                                              (301) 699-8706 Fax
                                              DWood@robertsandwood.com




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       Case 8:23-cr-00347-LKG         Document 56        Filed 12/23/24     Page 3 of 3



                               CERTIFICATE OF SERVICE
        I HEREBY CERTIFY that a copy of the foregoing Motion for Bond Review was
electronically filed on December 23, 2024, via the CM/ECF system. Notification of this filing
along with an electronic copy was delivered to:

                                  AUSA Nicholas Fish Potter
                                   6406 Ivy Lane, Suite 800
                                  Greenbelt, Maryland 20770
                                  nicholas.potter@usdoj.gov


                                             /s/ Douglas J. Wood
                                            Douglas J. Wood




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