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be N Ww ws Oo OY ~] oO WO Ww a OY 20 21 22 23 24 25 Case 1:19-cr-00830-AT Document 17 Filed 12/19/19 Page 13 of 15 13 JbpWnoeC MS. DONALESK Your Honor, with respect to modifying the travel restrictions, we have no objection to including her travel restriction to the Middle District of Pennsylvania. With respect to the firearm, defense counsel raised this in front of Judge Netburn last week, who had the opportunity to consult with pretrial services. She denied this request, as your Honor should do. We respectfully submit it is due to the safety concerns of pretrial services that the defendant should not be permitted to possess her firearm. The pretrial services officers have to go into the defendant's home, including at unscheduled visits, and due to their safety concerns with having a de know wher t h firearm is for pretrial services to surrender their firearms. Thi Ss 1s done in enforcement De surrender th officers who fendants are required to give eir firearms fendant who has access to a in the home, firearm and they may not it's ntirely reasonable say as a policy defendants have to every case, are on pretrial simply your Honor, including law services supervision. their for the safety of firearms back or to the pretrial services of fFicers who are going into their homes. And given that safety concern, we believe that it is appropriate, as Judge Netburn found, for that to be a condition of her release. THE COURT: The removal of the firearm is a commonsense safety measur The application is denied. SOUTHERN DISTRICT REPORTERS, P.C. (A127) 805-0200 DOJ-OGR-00021989