UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

UNITED STATES OF AMERICA )

)

 Plaintiff, )

) No. 12 CR 109

vs )

) Honorable Sharon Johnson Coleman

HEON SEOK LEE )

)

 Defendant. )

MOTION TO MODIFY CONDITIONS

OF PRETRIAL RELEASE TO PERMIT

EMPLOYMENT ACTIVITIES IN ILLINOIS

Now Comes Defendant, HEON SEOK LEE, by and through his attorney, 

Sheppard Law Firm, P.C., and pursuant to 18 U.S.C. § 3142(c)(3), moves this Court to 

allow him to work at KTurbo Inc.'s factory in Batavia, Illinois, as well as to travel to 

equipment supplier locations within Illinois, and attend client meetings or business 

meetings in Illinois. In support thereof, Mr. Lee states as follows: 

1. KTurbo Inc. has a factory at 1183 Pierson Drive, Unit 118, Batavia, Illinois, 

60510. See http://kturbousa.com/index. KTurbo is currently manufacturing oilfree air compressors. See id. There are currently only two employees at the 

factory in Batavia, David Choi and Martin Barson. 

2. As discussed at the last hearing in this cause, Mr. Lee's family resides in South 

Korea; they are dependent on income from KTurbo, Inc.

3. Mr. Lee is currently residing in Elk Grove Village. 

4. Mr. Lee is requesting permission to leave his home at or after 5 a.m., engage in 

work at KTurbo’s factory in Batavia, Illinois, and return home by 10 p.m..

Case: 1:12-cr-00109 Document #: 73 Filed: 06/29/16 Page 1 of 4 PageID #:258
5. If granted leave to do so, he would work seven days per week.

6. During the course of his employment, Mr. Lee may also be called upon to obtain 

equipment from an equipment supplier located within Illinois. 

7. As CEO of KTurbo, Inc., Mr. Lee's presence at sales meetings and other business 

events, such as at presentations to clients, is also critical to KTurbo's success. 

Accordingly, he is also requesting to attend employment activities outside the 

factory should the need arise. 

8. The Bail Reform Act lists “maintain employment” as one, of several, possible 

conditions “which will reasonably assure the appearance of the person as 

required and the safety of any other person and the community.” 18 U.S.C. 

3142(c)(B)(ii).

WHEREFORE, based on the foregoing, Mr. Lee moves this Court to allow him to 

work at KTurbo's factory in Batavia, Illinois, whereby he would leave his home at or 

after 5 a.m. and return by 10 p.m., and attend other employment activities, such as 

travelling to equipment supplier locations and sales meetings, within the time 

parameters described above.

Respectfully submitted:

/s/ Adam J. Sheppard

Attorney for Defendant

Adam Sheppard

Sheppard Law Firm, P.C.

180 N. LaSalle Street, Suite 2510

Chicago, Illinois 60601

(312) 443-1233

Illinois Bar No. 628737

Case: 1:12-cr-00109 Document #: 73 Filed: 06/29/16 Page 2 of 4 PageID #:259
CERTIFICATE OF SERVICE

I hereby certify that the foregoing motion was served on June 29, 2016, in 

accordance with Fed.R.Crim.P.49, Fed.R.Civ.P.5, LR 5.5, and the General Order on 

Electronic Case Filing (ECF) pursuant to the district court’s system as to ECF filers.

Respectfully submitted:

/s/ Adam J. Sheppard

Attorney for Defendant

Adam Sheppard

Sheppard Law Firm, P.C.

180 N. LaSalle Street, Suite 2510

Chicago, Illinois 60601

(312) 443-1233

Illinois Bar No. 62

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