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                                  UNITED STATES DISTRICT COURT  
               FOR THE DISTRICT OF COLUMBIA  
 
UNITED STATES OF AMERICA  
 
 V.      Case No.: 21 -cr-78 (EGS)  
 
 
JOHN SULLIVAN  
 
  STATUS REPORT CONCERNING CONDITIONS OF   
         PRETRIAL RELEASE  
 
 Undersigned counsel does hereby submit the following status rep ort  
 
concerning the conditions of defendant’s release:  
 
 1. Defend ant, his Utah pro bation officer, Mr. Cahoon , and 
undersigned counsel had a three way telephone conference  on August 2, 
2021. De fendant and Mr. Cahoon agreed as follows:  
 a. Employment:   Defend ant’s father/employer wil l submit to Mr. 
Cahoon a once a month e -mail confirming the work hours of defendant . 
Defend ant will  also keep track of his work hours and will provide notice of 
his hours to Mr. Cahoon. This is bei ng done in order to provide Mr. Cahoon 
with verification  of employment and defend ant’s work schedule.  
 b. Home visits : Mr. Cahoon will conduct random  home  visits which 
will occur  periodically  every couple of months. At the visit, Mr . Cahoon will Case 1:21-cr-00078-EGS   Document 40   Filed 08/03/21   Page 1 of 32 
 not have any disc ussion wi th defendant about the status of his pending 
case.  
 c. Contact  with probation office : Defendant will telephone, e -mail or 
have  text contact with Mr. Cahoon on a weekly basis. The com municati ons 
will contai n substantive in formation and provide updates on employment 
activities. On e time every other mon th defendant  will have an in -person 
meeting with Mr. Cahoon at his office  
 d. Computer monitoring : When Mr. Cahoon reaches out to 
defendant  conc erning monitoring issues, defend ant will reply in  a 
reasonable amo unt of time to address the issues . Defend ant will initiate 
contact with Mr. Cahoon if he believes there are any additional issues with 
computer monitoring.  
 2. The parties ag ree to cooperate with each other  going forward an d 
will advi se each other i f there are any  conc erns or questions regarding 
pretrial release.    
        
 
 
 
        Case 1:21-cr-00078-EGS   Document 40   Filed 08/03/21   Page 2 of 33 
        Respectfully submitted,  
 
       _______/s/_______________  
       Steven R. Kiersh #323329  
       5335 Wisconsin Avenue, N.W.  
       Suite 440  
       Washington, D.C. 20015  
       (202) 347 -0200  
 
                   CERTIFICATE OF SERVICE  
 
 I HEREBY CERTIFY that a true and accurate copy of the foregoing 
was served, via the Court’s electronic filing system, on this the 
____ 3rd____day of August , 2021 upon counsel of record, Candice Wong, 
Esquire, Assistant U.S. Attorney   
 
               
      ______ /s/____________________  
      Steven R. Kiersh  Case 1:21-cr-00078-EGS   Document 40   Filed 08/03/21   Page 3 of 3