IN THE UNITED STATES DISTRICT COURT FOR THE

NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION 

UNITED STATES, ) No. 12 CR 109

 )

) Judge Sharon Johnson Coleman

 vs. )

)

Heon Seok Lee

Motion to Modify Conditions of Release and Designate a

New Third Party Custodian 

Heon Seok Lee, defendant, by and through his attorney, Susan Shatz, 

respectfully moves this Honorable Court to Modify his Conditions of Release and to

designate a new third party custodian. Mr. Lee submits the following in support of his

Motion.

1. Mr. Lee’s aunt and uncle (the Hwangs) have been his third party custodians

for the last 10 months. During this time they have been unable to participate in many of

their normal activities. Mrs. Hwang has bourn the brunt of the third party custodian

responsibilities since Mr. Hwang returned to work, full time, last October. Shortly before

Mr. Lee began to reside with the Hwangs, Mrs. Hwang completed treatment for a

serious illness. She feels worn out and needs additional time to devote to her recovery. 

2. Mr. Lee’s mother, Kwnag Ja Kim came to the U.S. last November to assist

the Hwangs. She rented an apartment near the Hwangs home and has tried to pitch in.

3. Due to the stress Mrs. Hwang is feeling, it is respectfully requested that the

Court relieve the Hwangs of their third party custodian responsibilities and allow Mrs.

Kim to become Mr. Lee’s third part custodian.

Case: 1:12-cr-00109 Document #: 53 Filed: 02/19/16 Page 1 of 3 PageID #:183
4. Mrs. Kim understands and agrees that she will remain in the U.S. through the

completion of the trial. 

5. Undersigned counsel discussed this matter with pretrial services officer Justin

Wiersema. Mr. Wiersema met with Mrs. Kim during a recent visit to the Hwangs

residence. He agrees that Mrs. Kim would be an appropriate third party custodian with

the conditions that she:

1. Surrender her passport to pretrial services

2. Produce the lease on her apartment for verification

3. Agree to report to him immediately, if Mr. Lee violates any conditions of

his release

4. Agrees to remain in the U.S. through the completion of the trial; and 

5. That Mr. Lee remain on home monitoring.

6. Mr. Wiersema further stated that Mr. Lee has remained in compliance with all

the conditions of his bond to date and noted that a substantial bond was posted. 

Wherefore, it is respectfully requested that this Honorable Court modify the

conditions of Mr. Lee’s release and permit his mother to become his third party

custodian.

Susan Shatz Respectfully submitted,

53 W. Jackson Blvd. # 1615

Chicago, IL. 60604 S/Susan Shatz

312-697-0022 Susan Shatz

Attorney for Heon Seok Lee

Case: 1:12-cr-00109 Document #: 53 Filed: 02/19/16 Page 2 of 3 PageID #:184
CERTIFICATE OF SERVICE

I, Susan Shatz, an attorney, certify that I caused a copy of the above Heon Seok

Lee’s Motion to Modify the Conditions of Release, to be served by electronic filing

on February 19, 2016; 

on:

AUSA Patrick Otlewski

U.S. Attorney's Office

219 S. Dearborn St., 5th Floor

Chicago, IL 60604

Executed on, February 19, 2016

 S/ Susan Shatz_________________

Case: 1:12-cr-00109 Document #: 53 Filed: 02/19/16 Page 3 of 3 PageID #:185