Case: 4:12-cr-00009-RWS Doc. #: 40 Filed: 03/28/12 Page: 1 of 2 PageID #: 159
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`UNITED STATES DISTRICT COURT
`EASTERN DISTRICT OF MISSOURI
`EASTERN DIVISION
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`Case. No. 4:12-cr-009 RWS DDN
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`UNITED STATES OF AMERICA,
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`Plaintiff,
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`v.
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`SANDRA L. BEHE,
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`Defendant.
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`MOTION TO MODIFY CONDITIONS OF RELEASE
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`Defendant Sandra Behe, through undersigned counsel, hereby moves for modification of
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`the Order Setting Conditions of Release in order to permit her to travel in the Central District of
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`California without the written permission of the U.S. Pretrial Services Agency. In support of this
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`motion, the Defendant states:
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`1.
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`The Defendant is a resident of San Diego, California and lives approximately 30
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`miles from the southern border of the Central District of California, which includes the greater
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`Los Angeles area. The Order Setting Conditions of Release limits Defendant’s travel to the
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`Southern District of California absent the written permission of the U.S. Pretrial Services
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`Agency.
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`2. Consistent with the Order Setting Conditions of Release, Defendant is actively
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`seeking employment. Many of those opportunities are in the Los Angeles area and the current
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`travel restrictions impede her ability to arrange interviews and otherwise pursue employment
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`opportunities in that area. Wes Stephenson, Defendant’s Pretrial Services officer in the Southern
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`District of California, and Chaunsey Hunter, Defendant’s Pretrial Services officer in the Eastern
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`District of Missouri, have no objections to this modification of the conditions of release.
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`Case: 4:12-cr-00009-RWS Doc. #: 40 Filed: 03/28/12 Page: 2 of 2 PageID #: 160
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`3. Undersigned counsel has consulted with Assistant United States Attorney Andrew
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`Lay and he has no objection to this modification.
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`WHEREFORE, Defendant Sandra Behe requests the Order Setting Conditions of Release
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`be modified to permit her to travel within the Southern and Central Districts of California
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`without the prior permission of the U.S. Pretrial Services Agency.
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`HAAR & WOODS, LLP
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`/s/ Robert T. Haar
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`Robert T. Haar - #30044MO
`1010 Market Street, Suite 1620
`St. Louis, MO 63101
`(314) 241-2224
`(314) 241-2227 Telecopier
`edmofiling@haar-woods.com
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`Attorneys for Defendant Sandra Behe
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`CERTIFICATE OF SERVICE
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`I hereby certify that on the 28th day of March 2012, the foregoing was filed electronically
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`with the Clerk of the Court to be served by operation of the Court’s electronic filing system upon
`the following:
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`Andrew J. Lay
`Assistant United States Attorney
`111 South 10th Street, Suite 20.333
`St. Louis, Missouri 63102
`andrew.lay@usdoj.gov
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`/s/ Robert T. Haar
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