UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
UNITED STATES OF AMERICA
v.
RICHARD W. GATES III,
Defendant.

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Crim. No. 17-201-2 (ABJ)

DEFENDANT RICHARD W. GATES III’S MOTION TO MODIFY RELEASE
CONDITIONS FOR LIMITED PURPOSES
TO ATTEND NEW YEAR’S EVENTS
Richard W. Gates III, by and through counsel, hereby moves this Court for modification
of his release conditions for limited purposes so that he may accompany his family to events for
the New Year’s holiday from Sunday, December 31, 2017 through Monday, January 1, 2018.
The events are within the jurisdiction of the Eastern District of Virginia, less than 60 miles from
Mr. Gates’s residence. Mr. Gates requests a limited release to attend these events with his family
before school resumes 1. Mr. Gates notes that the Court denied a prior request to take a longer
trip with his family to a city outside the state of Virginia for the New Year’s holiday. Mr. Gates
submits this request with the hope that it is palatable to the Court given that the events span two
days instead of three and are within the Eastern of District Virginia, where Mr. Gates remains in
home confinement.
If this Court permits this limited release from home confinement, Mr. Gates will
promptly provide Pre-Trial Services with specific information about the events, including the
times and locations. Mr. Gates will also continue to abide by all of his other release conditions,
including reporting to Pre-Trial Services as well as maintaining his GPS monitor.
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See attached Exhibit 1 filed under seal for specific information about the events, including their
exact locations.

 The United States opposes this motion.
WHEREFORE, Mr. Gates hereby respectfully moves this Court to modify his release
conditions for limited purposes as specified above.
Respectfully submitted,
_/s/Shanlon Wu_______________
Shanlon Wu
D.C. Bar No. 422910
Wu, Grohovsky & Whipple, PLLC
Ronald Reagan Building and International
Trade Center
1300 Pennsylvania Avenue, NW, Suite 700
Washington, DC 20004
swu@dcwhitecollar.com
202-204-3053 (Telephone)
202-747-7518 (Facsimile)
Walter Mack
Admitted Pro Hac Vice
Doar Rieck Kaley & Mack
217 Broadway, Suite 707
New York, NY 10007-2911
212-619-3730 (Telephone)
212-962-5037 (Facsimile)
Annemarie McAvoy
Admitted Pro Hac Vice
McAvoy Consulting, LLC
mcavoypc@rocketmail.com
917-750-8131 (Telephone)
Attorneys for Richard W. Gates III

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 UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
UNITED STATES OF AMERICA
v.
RICHARD W. GATES III,
Defendant.

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)
)
)
)
)
)

Crim. No. 17-201-2 (ABJ)

ORDER
Upon consideration of Defendant Richard W. Gates III’s Motion to Modify Release
Conditions for Limited Purposes to Attend New Year’s Events and finding good cause shown, it
is this ___ day of December, 2017, hereby
ORDERED, that the motion is GRANTED.

_______________________________________
AMY BERMAN JACKSON
UNITED STATES DISTRICT JUDGE