Petition to Modify Conditions of Release

This document does NOT also include the original document.

Included in the document is a description of several mental conditions that Soloway has been diagnosed with and I'm not so heartless as to post that sort of information at this stage of the proceedings.

This will have the text version with that information redacted.

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United States District Court
Western District of Washington

Report on Defendant Under Pretrial Services Supervision
Name of Defendant
SOLOWAY, Robert

Bond Conditions Imposed:

6. Halfway house placement with release privileges as determined by Pretrial Services. You are required to make payments towards your subsistence at the halfway house in an amount determined by the halfway house, but not to exceed 25% of your income and/or the current daily rate. Pretrial Services will coordinate the defendant's release with the U.S. Marshals.

8. Travel is restricted to King County, Washington, or as directed by Pretrial Services. or as directed by Pretrial Services.

20. Undergo a mental health, psychiatric or psychological evaluation and follow all treatment recommendations in that evaluation, as directed by Pretrial Services. You shall take all medications as prescribed. 26. The defendant shall participate in the Workforce Development Program which may include participation in employment workshops, enrollment in a training or educational program, and/or actively seeking employment as directed by Pretrial Services.

30. Provide Pretrial Services with any requested information regarding your financial status, income sources, and investments. Sign a Release of Information form for Credit Bureau Verification if requested by Pretrial Services.

41. You shall not possess any Social Security number, identification, or documents in any name other than your own.

23. Do not use or possess a computer or electronic media, e.g. PDA (Personal Digital Assistant) and cellular phones, with internet access capabilities, or have anyone else on your behalf use or access a computer or electronic media, without prior approval of Pretrial Services. Do not access the internet, bulletin board systems, or private or public computer networks. Do not have others access, on your behalf, the internet, bulletin board systems, or private or public computer networks without prior approval of Pretrial Services.

45. Other The defendant shall not be self-employed in any cavacity. All employment shall be pre-approved by Pretrial Services.

35. You must contribute towards the costs of the services required by this bond, to the extent you are financially able to do so, as determined by Pretrial Services.

43. Comply with all other court orders or terms of supervision.

PETITIONING THE COURT

* To modify the conditions of supervision

DELETE:

Halfway house placement with release privileges as determined by Pretrial Services. You are required to make payments towards your subsistence at the halfway house in an amount determined by the halfway house, but not to exceed 25% of your income and/or the current daily rate.

-2 -
ADD;
Participate in the active Global Positioning Satellite Program and abide by all requirements of the program, under the direction of Pretrial Services.

Maintain residence as directed. Do not change residence without prior approval of Pretrial Services or as directed by Pretrial Services.

Submit to drug and alcohol testing, to include urinalysis, breathalyzer, or hand-held devices, as directed by Pretrial Services. You shall not use, consume or possess alcohol or any other product containing alcohol, including medication, unless prescribed to you by a physician and'under the direction of Pretrial Services. Obtain an evaluation for substance abuse/alcohol abuse counseling as directed by Pretrial Services.

CAUSE

The defendant has been a resident of Pioneer Fellowship House since his release from custody on September 18, 2007, According to halfway house staff, the defendant has been following all rules and regulations of the halfway house program and remains in full compliance with all program requirements. The defendant is also in full compliance with the conditions of bond and Pretrial Services supervision.

On October 9, 2007, the defendant began working full time at Leathercare, in Seattle, Washington, earning $9.00 dollars per hour. The defendant is responsible for checking in and ticketing clothing which has been in house fires. The clothing is then cleaned and returned to the owners. While the defendant does use a computer to do his work, Pretrial Services has confirmed with the defendant's employer that the computer does not have an Internet connection and the defendant has no access to client's financial information or access to cash or negotiable instruments. The defendant's supervisor stated the defendant is a quick learner and is proving to be a very good employee.

[REDACTED]

[REDACTED]

On October 19, 2007, this officer met with the defendant's parents who are currently in Seattle to secure a reasonably priced apartment for the defendant, in hopes the defendant will be released from the halfway house. The defendant's parents spoke candidly about the defendant's mental health issues and legal situation and indicated in no way did they want to enable the defendant. They are willing to pay the defendant's monthly rent and will not tolerate the lavish lifestyle the defendant was leading prior to his arrest. On October 22, 2007, the defendant's father, Herb Soloway, called this officer to report they were able to secure an apartment in the same building as the defendant's current apartment, for a third of the rent the defendant has been paying.

If the defendant is allowed to release from the halfway house, this officer recommends the defendant be ordered to submit to random drug and alcohol testing. The defendant stated to this officer he has remained clean and sober since releasing from custody, but felt the random testing would be a good incentive to maintain long term sobriety.

If allowed to release from the halfway house, it is also recommended the defendant be ordered to participate in the Global Positioning System (GPS) monitored closely by Pretrial Services Specialist, Brenda Amundson. With GPS, Officer Amundson would know the defendant's location at any given time. All movements by the defendant would require advanced approval. GPS would cost Pretrial Services $8.95 per day versus the halfway house which costs

$95.00 per day, currently being paid by Pretrial Services. The halfway house serves as short term transitional housing for defendants. It is Pretrial Services' goal to transition defendants out of the halfway house and back into the community within 30 days, thereby conserving the halfway house resource for other defendants. Strict monitoring of the defendant can be accomplished with the defendant residing at his own residence, with the added conditions of GPS and random substance abuse testing, to ensure he is not a risk of non-appearance or a risk of danger to the community.

The Assistant United States Attorney, Kathryn Warma, is opposing the defendant's release from the halfway house as she stated Pretrial Services can not control people coming to the defendant's residence with devices which would allow the defendant to access the internet. There are many internet cafes in close proximity to the halfway house were the defendant currently resides and although against the halfway house rules, many residents have cell phones with internet access. Frequent unannounced home visits by Pretrial Services will ensure the defendant has no computer equipment in his apartment.

Defense counsel has been notified and concurs with the recommendation. As noted above, the Assistant United States Attorney does not concur with the recommendation.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on this 23rd day of October 2007

Approved By.
Timothy W. McTighe
Chief U.S. Pretrial Services Officer

Connie Smith
Deputy Chief U.S. Pretrial Services Officer

THE COURT FINDS PROBABLE CAUSE AND DIRECTS:

* The Modification of Conditiops as noted above

J. Pechman, U.S. Ditrict Judge

Date: October 26, 2007

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