Case # 2:16-cr-00046-GMN-PAL-15
MOTION FOR RELEASE PENDING
SENTENCING AND OR APPEAL
Comes Now, Defendant Todd C. Engel, and moves this honorable court for an order
granting release pending the imposition of sentencing, presently scheduled for March 22nd, 2018,
or in the alternative release pending the outcome of an appeal to be filed challenging his
conviction by jury verdict of April 24th 2017.
This motion is timely, is made in accordance with the Local Rules of this Court, the
Federal Rules of Criminal Procedure, and 18 USC §3141 et seq, is not made for the purposes of
delay, and is based on a good faith position that the relief requested may be granted and is likely
to be granted by this court.
Respectfully submitted this 8th day of February 2018
/s/ Warren R. Markowitz, Esq
Warren R. Markowitz, Esq
Attorney for Defendant Todd C. Engel
