Unopposed Motion for Travel and to Modify Conditions of Release — No. 1:23-cr-00097 (Dkt. 29, N.D. Ill.)

Summary

Unopposed Motion for Travel and to Modify Conditions of Release, Document 29 in No. 23 CR 97 before Judge Elaine E. Bucklo in the Northern District of Illinois, Eastern Division, filed 04/11/23 by defence counsel. The defendant, charged with wire fraud and having pleaded not guilty on March 1, 2023, is restricted by her release conditions to the Northern District of Illinois but earns her living in part through entrepreneurial presentations that require travel. She seeks approval for trips to Jackson, MS on April 18 to April 20, the Bronx on April 29 to April 30 and Houston on May 11 to May 14, and asks that further travel within the continental United States need only be approved by her pre-trial services officer. The pre-trial officer and the Assistant United States Attorney were consulted on or around April 10, 2023 and do not oppose.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Full text

     Case: 1:23-cr-00097 Document #: 29 Filed: 04/11/23 Page 1 of 4 PageID #:117




                 IN THE UNITED STATES DISTRICT COURT
                FOR THE NORTHERN DISTRICT OF ILLINOIS
                           EASTERN DIVISION

UNITED STATES OF AMERICA,                        )
                                                 )
                    Plaintiff,                   )
                                                 )
v.                                               )   No. 23 CR 97
                                                 )
                                                 )   Judge Elaine E. Bucklo
                                                 )
TE DORA BROWN,                                   )
                                                 )
                    Defendant.                   )

                UNOPPOSED MOTION FOR TRAVEL AND TO
                   MODIFY CONDITIONS OF RELEASE

       Defendant, Te Dora Brown, by and through her attorney, Victor P. Henderson,

respectfully requests that this Court approve travel relating to business as described

below and to modify the conditions of her release to allow subsequent travel to be

approved by pre-trial and without the need to seek leave of Court. In support thereof,

Ms. Brown states as follows:

       1.    Ms. Brown was charged with wire fraud (Docket No. 1).

       2.    Ms. Brown pleaded not guilty on March 1, 2023 (Docket No. 9).

       3.    The conditions of Ms. Brown’s release restrict her travel to within the

Northern District of Illinois (Docket No. 13).

       4.    Ms. Brown earns her living, in part, by engaging in entrepreneurial

presentations, which require her to travel.

       5.    She has three upcoming trips in 2023. To wit:
    Case: 1:23-cr-00097 Document #: 29 Filed: 04/11/23 Page 2 of 4 PageID #:118




                  Place                                      Dates

              Jackson, MS                             April 18 – April 20

               Bronx, NY                              April 29 – April 30

              Houston, TX                              May 11 – May 14

      6.     She would like approval to take these trips.

      7.     In addition, Ms. Brown would like to modify the conditions of her release

so that she can travel within the continental United States without seeking leave of

Court. Instead, she would only need to obtain the approval of her pre-trial officer,

John Riehl

      8.     On or around April 10, 2023, counsel for Ms. Brown, Victor P.

Henderson, communicated with pre-trial services officer, John Riehl. He does not

oppose this motion.

      9.     On or around April 10, 2023, counsel for Ms. Brown, Victor P.

Henderson, communicated with AUSA Alejandro G. Ortega, who also informed

counsel that he does not oppose this motion.




                                          2
    Case: 1:23-cr-00097 Document #: 29 Filed: 04/11/23 Page 3 of 4 PageID #:119




      WHEREFORE, Ms. Brown respectfully requests that her conditions of release

be modified so that she can travel within the continental United States without

needing to seek permission from the Court, provided that pretrial has approved her

travel, and she also seeks approval of the three trips listed above and for such other

and further relief as this Court deems just.

DATED:       April 11, 2023



                                       Respectfully submitted,

                                       By:     /s/ Victor Henderson
                                               Attorney for Te Dora Brown
Victor P. Henderson
HENDERSON PARKS, LLC
140 South Dearborn, Suite 1020
Chicago, IL 60603
Phone: (312) 262-2900
Facsimile: (312) 262-2901
vphenderson@henderson-parks.com




                                          3
    Case: 1:23-cr-00097 Document #: 29 Filed: 04/11/23 Page 4 of 4 PageID #:120




                                CERTIFICATE OF SERVICE

       I hereby certify that on April 11, 2023, I electronically filed Defendant’s

UNOPPOSED MOTION FOR TRAVEL AND TO MODIFY CONDITIONS OF

RELEASE with the Clerk of the Court using the CM/ECF system which will send

notification of such filing to all counsel of record.


                                                         /s/ Victor P. Henderson




                                             4


File and source

File

29.pdf

Size

91,527 bytes

SHA-256

1f28f883dcf3158a14b515e6d82bd615348c220eb1b1875d9ccc843795926704

Our copy

29.pdf

Original

No public link identified.