Opinion
Criminal Docket No.: 3:09-000092
10-11-2012
UNITED STATES OF AMERICA v. SERGIO ACOSTA
Chief Judge Haynes
MOTION TO AUTHORIZE TRAVEL
COMES NOW the Defendant, Sergio Acosta, by and through his undersigned counsel and respectfully moves this Honorable Court to authorize him to travel to Atlanta, Georgia to attend an employment sponsored seminar from October 22 through October 27, 2012. In support of this Motion, the Defendant states the following:
1. On April 8, 2009, the Defendant Acosta was arrested by the Texas Department of Public Safety in Amarillo, Texas pursuant to a warrant from the Middle District of Tennessee charging him with Conspiracy to Distribute and Possession with Intent to Distribute Heroin. On April 29, 2009, the Defendant Acosta was released on a $25,000 secured bond with several conditions including pretrial services supervision. (Docket Entry no. 8).
2. Defendant Acosta appeared before this Court on his own volition and was released with minimal conditions of release. (Docket Entry no. 9, 10). One of the conditions of release is that Defendant Acosta's travel is limited to the Middle District of Tennessee and within a 75 mile radius of Phoenix, Arizona, where Defendant Acosta resides. Defendant