Case 1:17-cr-00201-ABJ Document 444 Filed 10/11/18 Page 1 of 3

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 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, (2) eliminate his curfew from 11:00pm – 7:00am, and (3)
expand the geographic area of travel for Mr. Gates to include the Eastern District of Virginia and
Washington, D.C. The Special Counsel has considered our request for these modifications and
has authorized the undersigned to represent that the Office does not oppose this motion.
Mr. Gates will continue to comply with his present obligations to report in person weekly
to Pre-Trial Services and to allow monthly inspections of his home. If the Court believes that
some additional restrictions are necessary to insure Mr. Gates’ attendance in Court, we suggest
that he be obliged to check-in weekly with Pre-Trial Services from his home using his home
telephone landline.
Mr. Gates’ conduct in pleading guilty and fulfilling the terms of his cooperation
agreement are part of the process he willingly embarked on to effect a course change in his life.
He understands that he will be sentenced by this Court, and he is committed to standing before
this Court to receive that sentence. He wishes the undersigned to affirm for him and to state
without hesitation that he is prepared to receive the Court’s sentence on whatever day it is
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 Case 1:17-cr-00201-ABJ Document 444 Filed 10/11/18 Page 2 of 3

imposed. His acknowledgment of his guilt, and his record of continuing cooperation throughout
this entire process, as well as his stated commitment to appear for sentencing, are the
underpinning for this motion and for the instant requests for modification of his conditions of
release.
The plea agreement contains very serious consequences for Mr. Gates should he violate
any of its terms or conditions. The advantages that attach to strict compliance with that
agreement, and the extraordinary disincentives to violating that agreement, alone guarantee Mr.
Gates’s appearance at any scheduled Court proceeding. Over a substantial period of time, now
approaching one year, Mr. Gates has demonstrated his resolve to comply with all conditions of
his release. Removing the GPS monitor and allowing Mr. Gates to travel within the Eastern
District of Virginia and District of Columbia without restriction will surely not increase the risk
of flight or make it less likely that Mr. Gates will appear in Court when required to do so. On a
much more personal note, removing the GPS monitor will contribute to the process of healing in
the Gates household which is on-going.
Following his release on conditions imposed by the Court, and during the weeks
preceding the entry of his plea of guilty, Mr. Gates began a period of active cooperation with the
Office of Special Counsel. Both before the entry of the plea, and for many weeks thereafter, Mr.
Gates, whenever requested, traveled to Washington, D.C., to appear at the Office of Special
Counsel to be interviewed as part of his cooperation agreement. Those sessions have been
numerous and they continue to this day. All of Mr. Gates’ effort was undertaken in strict
compliance with his release conditions, which the Court has previously modified to facilitate his
travel to meet with counsel and to attend the many debriefing sessions with the Special Counsel
without securing advance permission.

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 Case 1:17-cr-00201-ABJ Document 444 Filed 10/11/18 Page 3 of 3

These meetings with the Office of Special Counsel continued during the weeks preceding
the trial of co-defendant Paul Manafort in the United States District Court for the Eastern District
of Virginia. Mr. Gates testified at that trial, during which he acknowledged his own misconduct
and his pending sentencing by this Court. That process was especially painful for Mr. Gates, and
much of that pain was anticipated as he took the stand to testify. But that was part of his bargain
with the government, and he accepted the consequences. Following that trial, Mr. Gates has
continued to cooperate with the Special Counsel and with other federal investigators by attending
current meetings at which he provides additional information. In short, Mr. Gates has been a
model cooperating witness—making himself available to federal authorities whenever they have
requested his assistance. For these many reasons we believe this Court can conclude with
confidence that Mr. Gates will appear at every call of court and that he is deserving of the relief
requested herein.
WHEREFORE, Mr. Gates hereby respectfully moves this Court to modify his conditions
of release to remove the electronic GPS monitoring requirement and eliminate his curfew and the
restrictions on his geographical travel area as outlined in this motion. 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, D.C. 20005
tcgreen@sidley.com
(202) 736-8069 (telephone)
(202) 736-8711 (fax)
Attorney for Richard W. Gates III
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 Case 1:17-cr-00201-ABJ Document 444-1 Filed 10/11/18 Page 1 of 1

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 Unopposed Motion to Modify
Conditions of Release, and finding good cause shown, it is this ___ day of October, 2018, hereby
ORDERED, that the motion is GRANTED.

_______________________________________
AMY BERMAN JACKSON
UNITED STATES DISTRICT JUDGE