USA v. Pierucci et alMOTION to Modify Conditions of ReleaseD. Conn.January 20, 2015 UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA : No. 3:12-CR-238 (JBA) : v. : : FREDERIC PIERUCCI, : : Defendant. : January 20, 2015 MOTION FOR MODIFICATION OF CONDITIONS OF RELEASE For the reasons set forth below, defendant Frederic Pierucci hereby moves this Court for an extension of this Court’s November 24, 2014 order allowing him to remain in France until January 26, 2015, while he is on release on bail in the above-captioned case. In connection with this motion, we respectfully submit as follows: 1. On September 12, 2014, the Court granted Mr. Pie ucci’s consented motion to amend the conditions of his release to include travel from the United States to France (and all other European Union countries) during his release on bail in the above-captioned case for a period of eight weeks (until November 7, 2014). Per th terms of the Supplemental Order Setting Conditions of Release, Mr. Pierucci increased his original secured bond by $435,000. Additionally, Mr. Pierucci agreed to report to U. S. Probation by e-mail on a weekly basis. 2. At the time of the Order, Mr. Pierucci’s sentencing in the above-captioned case was set for December 10, 2014. On September 18, 2014, Mr. Pierucci’s sentencing was continued with no new date set. 4. On November 5, 2014, with the government’s consent, Mr. Pierucci moved to extend the Supplemental Order Setting Conditions of Release to permit him to remain abroad (in France or any other European Union country) until January 26, 2015, and to have him return to Case 3:12-cr-00238-JBA Document 191 Filed 01/20/15 Page 1 of 3 -2- . France on January 30, 2015, and remain there on the sam terms and conditions as stated in the Supplemental Order Setting Conditions of Release, until May 1, 2015. 5. On November 6, 2014, this Court granted Mr. Pierucci’s motion dated November 5, 2014. 6. Mr. Pierucci has complied with all his conditions of his release. 7. With the government’s consent, Mr. Pierucci hereby moves to extend the Supplemental Order Setting Conditions of Release to permit him to remain abroad (in France or any other European Union country) until March 2, 2015. Additionally, with the government’s consent, Mr. Pierucci would like to return to France on March 6, 2015, and remain there on the same terms and conditions as stated in the Supplemental Order Setting Conditions of Release, until May 1, 2015. Respectfully submitted, FREDERIC PIERUCCI By: /s/ Stanley A. Twardy Stanley A. Twardy, Jr. (ct05096) Day Pitney LLP One Canterbury Green 201 Broad Street Stamford, Connecticut 06901 (203) 977-7300 satwardy@daypitney.com and Elizabeth A. Latif (ct29055) Day Pitney LLP 242 Trumbull Street Hartford, Connecticut 06103 (860) 275-0100 elatif@daypitney.com His Attorneys Case 3:12-cr-00238-JBA Document 191 Filed 01/20/15 Page 2 of 3 -3- . CERTIFICATE OF SERVICE I hereby certify that on this date, a copy of the foregoing Motion will be electronically filed and served by mail on anyone unable to accept el ctronic service. Notice of this filing will be sent by e-mail to all parties by operation of the Court’s electronic filing system or by mail to anyone unable to accept electronic filing as indicated on the Notice of Electronic Filing. Parties may access this filing through the Court’s CM/ECF System. __/s/ Elizabeth Latif Case 3:12-cr-00238-JBA Document 191 Filed 01/20/15 Page 3 of 3