Case 1:17-cr-00201-ABJ Document 214 Filed 02/28/18 Page 1 of 2 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA UNITED STATES OF AMERICA v. RICHARD W. GATES III, Defendant. ) ) ) ) ) ) ) Crim. No. 17-201-2 (ABJ) DEFENDANT RICHARD W. GATES III’S UNOPPOSED MOTION TO MODIFY CONDITIONS OF RELEASE Richard W. Gates III, by and through counsel, respectfully requests this Court to modify his conditions of release. Mr. Gates asks the Court to (1) remove the requirement that he be subject to electronic GPS monitoring, and (2) remove the restrictions on his travel from his home in Richmond, Virginia, to the District of Columbia. The Special Counsel does not oppose this motion. Recent changes in circumstances warrant these modifications of Mr. Gates’s conditions of release. On February 23, 2018, Mr. Gates pled guilty to two counts of a criminal information. According to the terms of his plea agreement, he is now obliged to coordinate certain activities with the Office of Special Counsel. These obligations require his presence in Washington, D.C., often on short notice, and also require frequent consultation with undersigned counsel, whose office is also in Washington, D.C. In the past these arrangements have been delayed and made more complicated by the need to obtain permission to travel. The plea agreement contains very serious consequences for Mr. Gates should he violate any of its terms or conditions, which include an obligation to appear for all court proceedings. The advantages that attach to strict compliance with that agreement, and the extraordinary disincentives to violating that agreement, are more than sufficient to guarantee Mr. Gates’s 1 Case 1:17-cr-00201-ABJ Document 214 Filed 02/28/18 Page 2 of 2 appearance at any scheduled proceeding to include the date of sentencing. Removing the GPS monitor and allowing Mr. Gates to travel without restriction from Richmond to the District of Columbia will not increase the risk of flight or make it less likely that Mr. Gates will appear in Court when required to do so. Mr. Gates has fully complied with all the conditions of his release, and the proposed modifications will in no way alter any of the other conditions of release, with which Mr. Gates will continue to comply WHEREFORE, Mr. Gates hereby respectfully moves this Court to modify his conditions of release to remove the electronic GPS monitoring requirement and the restrictions on his travel to the District of Columbia. A draft order is attached. Respectfully submitted, /s/Thomas C. Green Thomas C. Green D.C. Bar No. 14498 Sidley Austin LLP 1501 K Street, N.W. Washington, DC 20005 tcgreen@sidley.com (202) 736-8069 (telephone) (202) 736-8711 (fax) Attorney for Richard W. Gates III 2 Case 1:17-cr-00201-ABJ Document 214-1 Filed 02/28/18 Page 1 of 1 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA UNITED STATES OF AMERICA v. RICHARD W. GATES III, Defendant. ) ) ) ) ) ) ) Crim. No. 17-201-2 (ABJ) ORDER Upon consideration of Defendant Richard W. Gates III’s Unopposed Motion to Modify Conditions of Release, and finding good cause shown, it is this ___ day of February, 2018, hereby ORDERED, that the motion is GRANTED. _______________________________________ AMY BERMAN JACKSON UNITED STATES DISTRICT JUDGE