UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF TEXAS

AUSTIN DIVISION

UNITED STATES OF AMERICA § 

§ 

§ 

§ 

§ 

§ 

V. CAUSE NO. A-20-CR-103(1) RP

JOHAN SHAREEF AL-SUHAIL

UNOPPOSED MOTION TO PERMIT DEFENDANT TEMPORARY ACCESS TO 

PASSPORT IN CUSTODY OF US PRETRIAL SERVICES

TO THE HONORABLE ROBERT PITMAN, UNITED STATES DISTRICT JUDGE, 

FOR THE WESTERN DISTRICT OF TEXAS, AUSTIN DIVISION:

COMES NOW Defendant Johan Shareef Al-Suhail, by and through her undersigned 

counsel, and moves this Court to permit Defendant's temporary access to his passport, showing the 

Court as follows:

I.

The Defendant, Johan Al-Suhail, awaits sentencing after entering a guilty plea to making 

a false statement, in violation of 18 USC 1001. 

II.

A month ago, Mr. Al-Suhail, misplaced his Texas Driver’s License. Mr. Al-Suhail has 

been unable to locate the Driver’s License and needs to replace it. The Texas Department of 

Public Safety requires that Mr. Al-Suhail show his passport to provide proof of his identity in 

order to replace his lost driver’s license. 
III.

US Pretrial Services has retained custody of Mr. Al-Suhail’s passport as a condition of 

release. US Pretrial Services Officer Albert Sierra advised counsel that a court order will be 

necessary to allow Mr. Al-Suhail to access his passport.

IV.

Mr. Al-Suhail therefore requests the Court to authorize US Pretrial Services to grant him 

temporary access to his passport as necessary to allow him to apply for a replacement Texas 

Driver’s license.

V.

The government has been consulted and does not oppose the Court granting this motion. 

U.S. Pretrial Officer Albert Sierra, who has been supervising Mr. Al-Suhail, has been consulted. 

FOR THESE REASONS, Defendant requests permission for temporary access to his 

passport. 

Respectfully submitted.

MAUREEN SCOTT FRANCO

Federal Public Defender

 /s/ JOSE I. GONZALEZ-FALLA

Assistant Federal Public Defender

Western District of Texas

Lavaca Plaza

504 Lavaca St., Ste. 960

Austin, Texas 78701 

(512) 916-5025

(512) 916-5035 (FAX)

Bar Number: Texas 08135700

Attorney for Defendant
CERTIFICATE OF SERVICE 

I hereby certify that on the 20th day of October, 2020, I electronically filed the foregoing 

Defendant’s Unopposed Motion To Permit Defendant Temporary Access to Passport In Custody 

of US Pretrial Services with the Clerk of Court using the CM/ECF system which will send 

notification of such filing to the following:

Michael C. Galdo

G. Karthik Srinivasan

Assistant U.S. Attorney

903 San Jacinto Blvd., Suite 334

Austin, TX 78701

/s/Jose I. Gonzalez-Falla
UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF TEXAS

AUSTIN DIVISION

UNITED STATES OF AMERICA § 

§ 

§ 

§ 

§ 

§ 

V. CAUSE NO. A-20-CR-103(1) RP

JOHAN SHAREEF AL-SUHAIL

O R D E R

On this date came on to be considered the Defendant’s Unopposed Motion to Permit 

Defendant Temporary Access to Passport in Custody of US Pretrial Services. After considering 

same the Court finds the motion should be Granted/Denied.

It is hereby Ordered that US Pretrial Services shall permit Mr. Al-Sahail to have temporary 

access to his passport for the purpose of applying for a new drivers license. Mr. Al-Suhail is to 

return the passport to US Pretrial Services upon completing his application for the driver’s 

license. The Court leaves at the discretion of US Pretrial Services how and when Mr. Al-Suhail is 

to receive and return the passport.

SIGNED THIS _______ DAY OF _____________________, 2020.

___________________________________________

ROBERT PITMAN

UNITED STATES DISTRICT JUDGE