Opinion
CASE NO.: 2:11-MJ-00510-GWF
08-15-2011
UNITED STATES OF AMERICA, Plaintiff, v. JACOB LILL, Defendant.
MICHAEL V. CRISTALLI, ESQ. Nevada Bar No. 6266 CRISTALLI & SAGGESE, LTD. Attorney for Defendant
MICHAEL V. CRISTALLI, ESQ.
Nevada Bar No. 6266
CRISTALLI & SAGGESE, LTD.
Attorney for Defendant
MOTION TO MODIFY PRETRIAL CONDITIONS OF SUPERVISION
COMES NOW, JACOB LILL, defendant herein, by and through his attorney MICHAEL V. CRISTALLI, ESQ., of the Law firm of CRISTALLI & SAGGESE, LTD., and respectfully moves this Honorable Court for a Motion to Modify Pretrial Conditions of Supervision.
This Motion is based on the attached Points and Authorities and any evidence and/or argument that may be adduced at a hearing in this matter.
MICHAEL v.CRISTALLI, ESQ.
Nevada Bar No. 6266
CRISTALLI & SAGGESE, LTD .
Attorney for Defendant
points and authorities
Defendant was placed on Pretrial Supervision with the stipulation that he is not to leave the jurisdiction. Defendant's grandmother, whom raised Defendant, presently resides in Colorado. She recently underwent emergency surgery in Colorado and is now in the Intensive Care Unit. This emergency surgery was unsuccessful and Defendant's grandmother is not expected to survive her current condition. Our office has spoken with Officer Terry Wheaton who is currently the Defendant's Pretrial Supervisor. Officer Wheaton does not have an objection to Defendant traveling to see his grandmother in Colorado as long as the GPS ankle monitor remains in place.
CONCLUSION
The Defendant respectfully prays that this motion be granted so his may visit his grandmother before she perishes.
MICHAEL v.CRISTALLI, ESQ.
Nevada Bar No. 6266
CRISTALLI & SAGGESE, LTD .
Attorney for Defendant
IT IS SO ORDERED this 15th day of August, 2011.
Peggy A. Leen
United States Magistrate Judge