Free Motion to Modify Conditions of Release - District Court of California - California

Case 4:07-mj-70574-MRGD

Document 27

Filed 10/31/2007

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1 J. TONY SERRA #32639

SARA ZALKIN #223044
2 506 Broadway

San Francisco CA 94133
3 Telephone: 415/986-5591 4 Attorneys for Defendant

MICHAEL MARTIN
5 6 7 8 9 10 11 UNITED STATES OF AMERICA, 12 13

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

Plaintiff, v.

CR 07-70574 WDB EX PARTE REQUEST TO MODIFY PRETRIAL RELEASE CONDITIONS /

14 MICHAEL MARTIN, 15 16 17

Defendant.

COMES NOW defendant, through counsel, and hereby requests

18 modification of conditions of release to allow travel throughout 19 the various districts located in the State of California, with 20 permission from United States Pretrial Services. 21 22

In support of said request, counsel declares: I am an attorney licensed to practice in the State of

23 California and before this court, and I am one of the attorneys 24 of record for defendant Michael Martin in this matter. 25

Mr. Martin already has business opportunities in the

26 Eastern District of California and anticipates additional 27 opportunities arising in southern California as well.
LAW OFFICES
506 BROADW AY SAN FRANCISCO (415) 986-5591 Fax: (415) 421-1331

28 Specifically, Mr. Martin leases an inflatable device for

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Case 4:07-mj-70574-MRGD

Document 27

Filed 10/31/2007

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1 children's parties and events known as a "Bouncy House" that he 2 rents for such occasions. 3

The requested modification would conserve judicial

4 resources by avoiding repeated requests for permission to travel 5 within California while this matter is pending. 6

Hence Williams of United States Pretrial Services has no

7 objection and, in fact, suggested the requested modification. 8 Shashi Kewalramani, counsel for the government, likewise has no 9 objection. 10

It is therefore respectfully requested that Mr. Martin's

11 conditions of pretrial release be modified as indicated. 12

I declare under penalty of perjury that the foregoing is

13 true and correct, and that this declaration is executed on 14 October 31, 2007, at San Francisco, California. 15 16 17 18 19 20 21 22 23 24 25 26 27
LAW OFFICES
506 BROADW AY SAN FRANCISCO (415) 986-5591 Fax: (415) 421-1331

/s/ SARA ZALKIN SARA ZALKIN Attorney for Defendant MICHAEL MARTIN

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