DOJ-OGR-00021989.pdf

Case 1:19-cr-00830-AT Document 17 Filed 12/19/19 Page 13 of 15 1 MS. DONALESKI: Your Honor, with respect to modifying 2 the travel restrictions, we have no objection to including her 3 travel restriction to the Middle District of Pennsylvania. 4 5 With respect to the firearm, defense counsel raised 6 this in front of Judge Netburn last week, who had the 7 opportunity to consult with pretrial services. She denied this 8 request, as your Honor should do. 9 10 We respectfully submit it is due to the safety 11 concerns of pretrial services that the defendant should not be 12 permitted to possess her firearm. The pretrial services 13 officers have to go into the defendant's home, including at 14 unscheduled visits, and due to their safety concerns with 15 having a defendant who has access to a firearm and they may not 16 know where the firearm is in the home, it's entirely reasonable 17 for pretrial services to say as a policy defendants have to 18 surrender their firearms. 19 20 This is done in every case, your Honor, including law 21 enforcement officers who are on pretrial services supervision. 22 Defendants are required to give their firearms back or to 23 surrender their firearms simply for the safety of the pretrial 24 services officers who are going into their homes. And given 25 that safety concern, we believe that it is appropriate, as THE COURT: The removal of the firearm is a commonsense safety measure. The application is denied. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00021989