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Motion to Modify Conditions of Release — No. 1:23-cr-00027 (Dkt. 43, D. Md.)

Summary

Tomeka Glenn, through attorney Christopher C. Nieto, asks the U.S. District Court for the District of Maryland in Criminal Case No. RDB-23-0027 to remove the 9:00pm to 8:30am curfew imposed as a condition of her pretrial release. The motion, filed 11/27/23 as Document 43, says the Government did not seek detention at her initial appearance on January 6, 2023, when she was placed on electronic home monitoring, and that on August 18, 2023, after seven months of compliance, the monitoring was replaced with the curfew. It states that she has complied with all her conditions. Probation Officer Vicky Adams supports the change and the Government, through Assistant United States Attorney Paul Riley, opposes it; after contacting Magistrate Judge Coulson's chambers, the parties agreed to a hearing on Thursday, December 7, 2023, at 10:30am, which the motion asks the Court to schedule.

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Full text

         Case 1:23-cr-00027-RDB Document 43 Filed 11/27/23 Page 1 of 2


                    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 has been satisfactory throughout the past three months: she has had no

issues with her supervising officer and has complied with all the conditions of her release.

         3.         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



                                            −1−
       Case 1:23-cr-00027-RDB Document 43 Filed 11/27/23 Page 2 of 2


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

of this case.

        4.         Undersigned counsel has spoken with both Assistant United States

Attorney Paul Riley and United States Probation Officer Vicky Adams about this request.

Agent Adams is in support of this modification, but the Government opposes this request.

Accordingly, we respectfully request a hearing for the Court to rule on this motion. In

anticipation of this hearing, counsel for both Ms. Glenn and the government contacted

Magistrate Judge Coulson’s chambers, and the parties have agreed to conduct this hearing

on Thursday, December 7, 2023, at 10:30am.

        WHEREFORE, Ms. Glenn respectfully requests that the Court schedule a hearing

for the above-referenced date and 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 November 27, 2023, 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


                                           −2−


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