UNOPPOSED MOTION TO MODIFY CONDITIONS OF RELEASE

C.W. HOFFMAN, Jr., Magistrate Judge.

The Defendant, Marcus Richardson, through his attorney, Rene L. Valladares, Federal Public Defender, and Rebecca Levy, Assistant Federal Public Defender, respectfully moves this Honorable Court to modify condition of his release.

ARGUMENT

On September 30, 2016, Mr. Richardson made his initial appearance on a complaint alleging, a violation of 21 U.S.C. §§ 841(a)(1) and (b)(1)(C), Conspiracy to Distribute Heroin. Docket #1. Mr. Richardson was released with certain conditions. One of those conditions, #32, requires Mr. Richardson to avoid all contact directly or indirectly with the co-defendant(s) unless in the presence of counsel. Mr. Richardson is requesting this condition be removed. The government and Pre-Trial Services have no objection to this request.

Co-defendant, Johnny Tovar, is Mr. Richardson's brother-in-law. Mr. Richardson's wife has custody of her younger brother and sister. These siblings are also Mr. Tovar's siblings. The condition preventing contact between the co-defendant's prevents Mr. Tovar and his younger siblings from having contact. This condition has also prevented Mr. Tovar from having contact with his sister, Mr. Richardson's wife. Likewise, Mr. Epps is a very close family friend who has been a part of the Richardson's family for a long time.

The government does not object to this request nor does Pre-Trial Services. Ms. Richardson has been compliant since his release.

CONCLUSION

Accordingly, we are respectfully requesting this modify the conditions of Mr. Richardson's release to remove the condition of no contact with co-defendants.