DOJ-OGR-00021987.pdf

Case 1:19-cr-00830-AT Document 17 Filed 12/19/19 Page 11 of 15 11 JbpWnoeC her ability to actually possess her firearm should her job status change, meaning there may become a change in her ability to carry it publicly because of a change of job situation, but it won't impact her constitutional right to actually bear arms. Under 3142, the Court should consider the least restrictive methods, in this case, I think, address the safety issue being raised by pretrial services. If you look at Ms. Noel's history and character, she doesn't have a prior criminal record. She has no history of violence or bad conduct that might indicate that she is a physical threat, that she would use her firearm against another unwarrantedly. The pretrial services report was done by the person who's going to supervise her. I've had an opportunity to speak to pretrial services about this application, that I would be making this application, and fortunately, having worked with the pretrial services officer, he respectfully disagreed with my position and mentioned to me that one of the concerns is what happens if I come to the home and the gun is out? That's a problem. Well, it could be a problem, I suppose, but it's not like a dog who has its own will and may go bite someone. In fact, I submit to the Court that if my client had a dog that wasn't friendly to strangers, that one of the remedies we would say is when they come from pretrial services, you have to put SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00021987