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

Case 1:07-cr-00106-JJF

Document 46

Filed 04/24/2008

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v. DAYWON DRUMMOND Defendant.

: : : : : : : : :

Criminal Action No. 07-106-JJF

MOTION TO MODIFY CONDITIONS OF RELEASE Defendant, Daywon Drummond, by and through his undersigned counsel, Luis A. Ortiz, hereby moves this Court for an Order modifying his conditions of release. In support thereof, Mr. Drummond avers as follows: 1. On or about July 24, 2007, Daywon Drummond was released following a detention

hearing. As a condition of his release, Mr. Drummond was placed on home confinement. 2. Daywon Drummond seeks a modification of his release conditions by lifting the

requirement of home confinement with electronic monitoring. Mr. Drummond has numerous child care, counseling, and work related reasons which merit this request. 3. Assistant United States Attorney, Edmond Falgowski, is not opposed to this request.

United States Probation Officer, Craig H. Carpenter, is also not opposed to this request.

Case 1:07-cr-00106-JJF

Document 46

Filed 04/24/2008

Page 2 of 2

WHEREFORE, it is respectfully requested that this Court enter an Order modifying the conditions of Mr. Drummond's release permitting him to no longer be on home confinement. Respectfully submitted,

/s/ Luis A. Ortiz LUIS A. ORTIZ Assistant Federal Defender Federal Public Defender's Office One Customs House 704 King Street, Suite 110 Wilmington, DE 19801 (302) 573-6010 [email protected] Attorney for Defendant Daywon Drummond

DATE: April 24, 2008

2

Case 1:07-cr-00106-JJF

Document 46-2

Filed 04/24/2008

Page 1 of 1

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff, v. DAYWON DRUMMOND Defendant.

: : : : : : : : :

Criminal Action No. 07-106-JJF

ORDER AND NOW, this _________ day of __________________, 2008, it is hereby ORDERED that the pre-trial release Order for Daywon Drummond is modified to lift the requirement of home confinement with electronic monitoring.

BY THE COURT:

_____________________________ Honorable Joseph J. Farnan, Jr. United States District Court