Case 1:12-cr-00135-RJL Document 22 Filed 03/01/13 Page 1 of 3 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA UNITED STATES OF AMERICA v. KWAME R. BROWN, Defendant : : : : : : : : Criminal No. 1:12-cr-00135 EMERGENCY UNOPPOSED MOTION OF DEFENDANT TO TRAVEL AND TO MODIFY CONDITIONS OF HOME DETENTION Defendant Kwame R. Brown (hereinafter "Defendant"), by and through undersigned counsel respectfully submits his unopposed motion to travel outside of the Washington, D.C. Metropolitan area from March 9, 2013 to March 10, 2013, and to modify the terms of his home detention to accommodate that travel. As reasons for the grant of this motion, Defendant states as follows: 1. On November 13, 2012, this Court sentenced Defendant, inter alia, to two (2) years of supervised release. The first one hundred eighty (180) of that supervised release was to be served with electronic monitoring and a curfew for Defendant was imposed from 10PM to 6AM. 2. Over the past four (4) years, Defendant has helped over 550 District students from low-income families visit colleges as part of a College Roundup program. The College Roundup is a one-day bus trip to North Carolina where students meet and interview with college recruiters. District students bring their high school transcripts and their SAT scores for immediate review by the college recruiters. The College Roundup program has been successful in getting college application fees waived. In some cases, the District students received acceptance letters on the Case 1:12-cr-00135-RJL Document 22 Filed 03/01/13 Page 2 of 3 spot. 3. This year's College Roundup trip is on March 9, 2013. As in past years, the bus will leave at 4AM for North Carolina, and return sometime very late that on the evening of March 9, 2013, and maybe after midnight on March 10, 2013. 4. Participation in the College Roundup trip will allow Defendant to continue the important work of taking these students from low-income families to North Carolina to talk to college recruiters. Additionally, the Campus Roundup trip will be another opportunity to talk to young people about the value of obeying the law. 3. Undersigned counsel represents that the instant motion is unopposed by the Government. Additionally, Defendant is compliance with all of the terms of his supervised release, and Defendant's probation officer does not oppose the grant of this request. WHEREFORE, Defendant respectfully requests that this Court grant Defendant permission to travel from the Washington, D.C. metropolitan area on March 9, 2013 with a return no later than 2AM on March 10, 2013, and to modify the conditions of his home detention to allow Defendant to leave his home at 2AM on March 9, 2013, and to return to his home no later than 2AM on March 10, 2013. Respectfully submitted, /s/ Frederick D. Cooke, Jr. ________________________________________ Frederick D. Cooke, Jr., D.C. Bar No. 164608 Rubin, Winston, Diercks, Harris & Cooke, LLP 1201 Connecticut Avenue, NW, Suite 200 Washington, D. C. 20036 202 861 0870 202 429 0657 (facsimile) Counsel for Defendant Kwame R. Brown Case 1:12-cr-00135-RJL Document 22 Filed 03/01/13 Page 3 of 3 CERTIFICATE OF SERVICE I, Frederick D. Cooke, Jr., do hereby certify that on this 1st day of March, 2013 a copy of the foregoing Emergency Unopposed Motion was caused to be served by ECF to the following: Mary Connor, Esq. David S. Johnson, Esq. Assistant United States Attorneys Office of the United States Attorney for the District of Columbia 555 4th Street, NW Washington, D.C. 20530 /s/ Frederick D. Cooke, Jr. ___________________________________ Frederick D. Cooke, Jr