Texas bond conditions defense

The statutory framework for Texas bond conditions

Texas bond conditions live in CCP Chapter 17 — Art. 17.40 supplies the general authority and reasonableness standard; Arts. 17.41, 17.42, 17.44, 17.49, 17.441, and 17.292 supply category-specific frameworks. Every condition imposed must trace back to a statutory anchor and the two-purpose test of appearance plus safety.

CCP Art. 17.40 — general bond conditions

The general authority. The magistrate or trial court may impose any condition reasonably necessary to (1) ensure the defendant's appearance at trial and (2) ensure the safety of the victim or the community. The two-prong purpose is the universal reasonableness test — a condition that does not advance either purpose is vulnerable on motion to modify. Art. 17.40(b) provides the modification mechanism: conditions can be added, removed, or altered on a showing of changed circumstances or where the condition no longer serves the statutory purpose. Aviles v. State, 23 S.W.3d 74 (Tex. App.—Houston [14th Dist.] 2000), supplies the abuse-of-discretion review standard on appeal.

CCP Art. 17.42 — personal-bond office and personal-bond conditions

Personal-bond offices established under Art. 17.42 screen defendants for release on personal bond (release on a written promise to appear without posting cash or surety). Screening uses risk-assessment instruments and criminal-history checks. Personal-bond conditions are typically more involved than cash-bond conditions because release is liberty-only — common conditions include weekly reporting, residence verification, drug testing, no-contact, and employment verification. Many Texas counties operate personal-bond programs that significantly reduce pretrial jail population for low-risk defendants. Counsel's first move in many cases is to advocate for personal-bond release with structured conditions rather than cash bond.

CCP Art. 17.44 — home confinement and electronic monitoring

Home-confinement conditions and electronic monitoring (typically GPS monitoring) are authorized under Art. 17.44. The defendant remains at a designated residence except for court appearances, work, education, medical appointments, and other court-approved activities. GPS ankle devices report location data continuously; tampering or zone violations generate immediate alerts. Common in family-violence cases with stay-away conditions, in stalking cases, in serious-bodily-injury cases, and in any case where the court finds heightened risk. Costs run $250-$400 installation plus $10-$15/day vendor fee, borne by the defendant. The financial burden alone supports a reasonableness challenge in many cases.

CCP Art. 17.441 — DWI ignition-interlock-conditioned bond

The ignition interlock device requirement is mandatory under Art. 17.441 for any defendant charged with a second or subsequent DWI offense. For a first DWI bond, the interlock condition is discretionary — the court may impose it upon finding it necessary, and must impose it where statutory aggravators apply (open container, child passenger, BAC 0.15 or above, intoxication assault, intoxication manslaughter under PC § 49.07 / § 49.08). The device records every engine-start attempt, rolling-retest result, and tamper event; records are reported monthly. The defendant pays $75-$150 installation plus $70-$90/month service fee.

CCP Art. 17.49 — pretrial drug testing programs

Art. 17.49 authorizes pretrial drug-testing programs as a bond condition. The court may order initial and periodic testing — typically random urinalysis with confirmation testing — with positive results reported to the court. A positive test is grounds for bond modification or revocation under Art. 17.40. Cost is typically $25-$50 per test, borne by the defendant. The condition is challengeable where the underlying offense has no substance-abuse nexus (e.g., a property-crime defendant with no drug-related conduct) or where the testing burden is unreasonable in light of the defendant's employment and life circumstances.

CCP Art. 17.292 — emergency protective order overlay

In family-violence, sexual-assault, stalking, and trafficking cases, the magistrate issues an emergency protective order (EPO) at magistration that operates as a bond-condition overlay. Duration is 31 to 91 days (minimum 61 days where firearms or serious bodily injury are involved). Standard EPO terms include no-contact with the protected person, stay-away zone around the residence and workplace, firearm prohibition, and license-to-carry suspension. The EPO terms layer on top of any conditions imposed under Art. 17.40 and create overlapping enforcement exposure under PC § 25.07 (criminal) and Art. 17.40 (bond revocation).

The statutory architecture matters because every condition imposed must trace back to one of these provisions and must satisfy the Art. 17.40 reasonableness test. A condition imposed without a statutory anchor — or a condition that does not advance the two-purpose test of appearance plus safety — is vulnerable on motion to modify. The Eighth Amendment's prohibition on excessive bail and the parallel Texas guarantee in Article I, § 11 of the Texas Constitution apply to conditions as well as to the bond amount itself. Stack v. Boyle, 342 U.S. 1 (1951), set the federal framework — bail is excessive when set higher than reasonably calculated to ensure presence at trial. Ex parte Anderer, 61 S.W.3d 398 (Tex. Crim. App. 2001), addressed proportionality of conditions in the Texas context. Counsel begins every bond-conditions case by mapping the imposed conditions against the statutory framework and identifying which conditions are mandatory (e.g., Art. 17.441 interlock for second-DWI), which are discretionary, and which can be attacked on reasonableness or proportionality grounds.

Mandatory vs. discretionary conditions — knowing the difference

A handful of Texas bond conditions are statutorily mandatory — ignition interlock for second-DWI under Art. 17.441, EPO firearm-surrender under Art. 17.292(c), certain HIV testing under Art. 17.41 — but the majority are discretionary, and every discretionary condition is attackable for non-fit to the case.

The first analytical move on any bond-conditions case is sorting the imposed conditions into mandatory and discretionary buckets. Mandatory conditions cannot be removed by motion to modify because the statute compels them — counsel's leverage on mandatory conditions is limited to negotiating implementation details (vendor selection, monitoring frequency, financial-burden alternatives) and to challenging the threshold trigger (e.g., whether the offense actually qualifies as a "second DWI" for Art. 17.441 mandatory interlock). Discretionary conditions, by contrast, are fully attackable on Art. 17.40(b) modification motion and on reasonableness grounds under the appearance-and-safety test.

The mandatory category in Texas is narrow but important. Under Art. 17.441(a), interlock is mandatory for any defendant charged with a second or subsequent DWI offense — the court has no discretion to omit the device, though the court does have discretion over the BAC threshold (typically 0.025 to 0.05) and monitoring frequency. Under Art. 17.292(c), where a magistrate finds family violence occurred, the EPO must include firearm-prohibition and license-to-carry-suspension provisions for the order's pendency. Under Art. 17.41, HIV testing is mandatory in certain sexual-assault cases on victim request. PC § 25.07 and the parallel EPO terms create their own mandatory-overlay structure in family-violence cases.

Discretionary conditions — which is most of them — are vulnerable to reasonableness challenges. A no-contact order is discretionary in most non-FV cases; a stay-away zone is discretionary; GPS monitoring is discretionary except where a court finds specific need; drug testing under Art. 17.49 is discretionary; curfew is discretionary; travel restriction is discretionary. Each discretionary condition imposed must be specifically tied to the appearance-or-safety purpose of Art. 17.40. Conditions imposed by template — by magistrate-court routine rather than by case-specific findings — are vulnerable on the record because the magistrate often did not articulate why the specific condition was necessary in the specific case. We obtain magistration recordings, body-cam audio of the magistration hearing, and the magistrate's docket notes to map exactly what findings (if any) supported each discretionary condition.

Family-violence condition overlay under CCP Art. 17.292

In family-violence cases, the Art. 17.292 emergency protective order (EPO) creates a separate condition overlay on top of any Art. 17.40 conditions — no-contact, stay-away, firearm surrender, and license-to-carry suspension for 31 to 91 days. The overlap with Art. 17.40 conditions and PC § 25.07 violation exposure makes coordination essential.

CCP Art. 17.292 is the family-violence condition overlay. When a defendant is arrested for an offense involving family violence (as defined in Family Code § 71.004), sexual assault, stalking, or trafficking, the magistrate must consider entering an EPO at the magistration hearing. In some configurations the EPO is mandatory (firearm use, serious bodily injury under Art. 17.292(j)); in others it is discretionary on the magistrate's finding of likely future risk. The EPO's standard terms — no contact with the protected person, stay-away from the residence and workplace, firearm surrender, license-to-carry suspension — operate independently of any Art. 17.40 conditions and run 31 to 91 days from the date of issuance.

The overlay creates layered enforcement exposure. A violation of the Art. 17.40 no-contact bond condition is grounds for bond revocation under Art. 17.40(b) and for bond forfeiture under bond forfeiture under CCP Art. 22. The same conduct violating the Art. 17.292 EPO is a separate criminal offense under PC § 25.07 — Class A misdemeanor default, third-degree felony on enhancement. A single contact with the protected person can therefore produce (1) bond revocation, (2) bond forfeiture, and (3) a new § 25.07 prosecution. Defense counsel must coordinate the EPO defense at the Art. 17.292(j) modification hearing (within 14-21 days of issuance) with the bond-conditions defense on motion to modify under Art. 17.40(b), and with parallel preparation for any § 25.07 violation prosecution.

Firearm-surrender conditions under Art. 17.292(c) and parallel Art. 17.40 conditions are particularly fraught. The order requires surrender of all firearms to a non-prohibited third party — typically a non-resident family member, a friend, or a licensed FFL holder for storage. Federal 18 U.S.C. § 922(g)(8) firearm prohibition does not attach to an EPO alone (that prohibition tracks Family Code Chapter 85 final POs and similar after-notice orders), but Texas Penal Code § 46.04(c) does prohibit firearm possession during the EPO's pendency. A defendant who possesses any firearm during the EPO's 31-91 day pendency commits a separate Texas crime. Counsel coordinates the documented transfer at intake — written receipt, photograph of the items, and confirmation of the non-prohibited status of the recipient.

DWI interlock under CCP Art. 17.441

The ignition interlock device requirement is mandatory under Art. 17.441 for any second-DWI bond and discretionary for first-DWI bond. The device's cost, monitoring, and tamper-event reporting create their own enforcement framework — and an attack surface where statutory aggravators are not present or where the offense classification is contested.

CCP Art. 17.441 is the DWI bond-condition anchor. Subsection (a) makes interlock mandatory for any defendant charged with a "subsequent" DWI offense — defined to include DWI 2nd, DWI 3rd, and any felony DWI charge. The mandatory trigger turns on the offense classification at the time of bond setting, not on whether prior DWIs were charged as enhancements. Where the State alleges a prior DWI to enhance the present case, interlock attaches at bond. Where the State has not yet decided on enhancement (or where the prior DWI is contested as not qualifying), counsel can challenge the interlock attachment at magistration or on motion to modify.

For a first DWI bond, Art. 17.441(b) makes interlock discretionary but lists aggravators that effectively make it mandatory in practice: BAC 0.15 or above (charged as Class A misdemeanor under PC § 49.04(d)), open-container present in the vehicle, child passenger under PC § 49.045, intoxication assault under PC § 49.07, intoxication manslaughter under PC § 49.08. Where any of these aggravators is alleged, interlock attaches. Where none is alleged — a clean first-offense DWI with BAC under 0.15, no aggravators — the magistrate has discretion and the condition is attackable for first-DWI bonds.

The device itself records every engine-start attempt and every rolling-retest result; the monitoring vendor produces monthly reports to the court. A positive reading (typically above 0.025 BAC) generates an immediate alert. A tamper event — disconnection, circumvention attempt, or failure to provide a retest — is also reported and is treated as a bond violation. Defense counsel reviews the monthly reports for false-positive readings (mouthwash, residual fermentation on the breath, environmental contamination) and challenges any violation finding based on a contested positive. Where the defendant's employment requires driving a company vehicle, an occupational-license carve-out under Tex. Transp. Code § 521.241 can sometimes be coordinated with the interlock condition to permit limited business use — but the carve-out is narrow and requires specific findings from the court.

The motion-to-modify mechanism under CCP Art. 17.40(b)

CCP Art. 17.40(b) supplies the universal modification mechanism. The defendant (or the State) may move at any time for addition, removal, or alteration of any condition on a showing of changed circumstances or where the condition no longer serves the statutory purpose. The standard is abuse of discretion on appeal; the practical leverage is record-building below.

CCP Art. 17.40(b) provides the universal modification path. Either party — the defendant or the State — may file a motion to modify conditions at any point during the pendency of the case. The court holds a hearing, considers evidence, and rules. The standard for modification is whether the condition continues to serve the Art. 17.40 two-purpose test of appearance and safety, given the present circumstances of the defendant and the case. Ex parte Davila, 623 S.W.2d 408 (Tex. Crim. App. 1981), addressed the modification standard in the bond-conditions context.

Successful modification motions require record-building. Counsel develops evidence supporting the requested modification: clean drug-test results over a sustained period (to support drug-testing condition removal), stable employment and residence (to support GPS condition removal), voluntary completion of treatment or counseling (to support condition relaxation in DWI or family-violence cases), the complainant's changed position (to support no-contact modification where the complainant supports modification, although the complainant's consent is not dispositive in family-violence cases under Art. 17.292), and changed life circumstances (employment requirements supporting travel-restriction relief, family obligations supporting curfew relaxation, medical or educational needs supporting condition modification).

The motion-to-modify procedure follows the standard motion practice in the underlying criminal case — written motion filed with the court, service on the State, hearing within a reasonable time (typically 14-30 days), evidence presented by both sides, ruling by the trial court. The standard on appellate review is abuse of discretion under Aviles v. State, 23 S.W.3d 74 (Tex. App.—Houston [14th Dist.] 2000) — a high bar, which means the practical leverage is at the trial-court level. Persistent, well-supported modification motions throughout the pendency of the case typically secure incremental relief: GPS removed after six months of clean compliance, drug-testing frequency reduced after 90 days of clean tests, travel restriction relaxed to permit out-of-state work travel, curfew lifted after employment stabilization. The cumulative effect of multiple modifications over the pretrial period can dramatically reduce the burden of the conditions on the defendant's daily life.

Consequences of violating a bond condition

Violating a bond condition triggers two parallel procedures: bond revocation under CCP Art. 17.40 and bond forfeiture under CCP Chapter 22. The revocation hearing has the lower burden; forfeiture is a civil-collection proceeding against the surety. Coordinated defense at both procedures is essential.

A violation of a bond condition triggers two distinct procedures with two distinct sets of stakes. First, bond revocation under Art. 17.40. The State files a motion to revoke bond, the court holds a hearing, and on a showing of violation by a preponderance of the evidence, the court may revoke the bond and remand the defendant to custody pending trial. The revocation hearing is conducted in the criminal case; the defendant has counsel, may present evidence, and may cross-examine the State's witnesses. The hearing has a lower burden than the original detention hearing and lower than the burden at trial — preponderance, not beyond reasonable doubt. Smith v. State, 829 S.W.2d 885 (Tex. App.—Houston [1st Dist.] 1992), addressed habeas review of pretrial conditions and revocation.

Second, bond forfeiture under CCP Art. 22. The forfeiture is a separate civil-collection proceeding against the surety (or against the defendant on personal bond) to collect the face amount of the bond. The process begins with a judgment nisi under Art. 22.02 when the court calls the case and the defendant does not appear (or, in some configurations, when a condition is violated). Service is made on the sureties under Art. 22.04. A final-judgment hearing under Art. 22.13 follows, at which the defendant and the surety may present defenses — death or incarceration in another jurisdiction, sickness preventing appearance, or other showings that the nonappearance was not willful. The forfeiture proceeding runs parallel to the criminal case and continues to require defense even after the criminal case resolves.

Defense at the revocation hearing focuses on (1) the existence of the violation (did the alleged conduct actually constitute a violation of the specific condition imposed?), (2) the defendant's knowledge of the condition (was the condition sufficiently specific and was it adequately communicated?), (3) the willfulness of the violation (was the conduct intentional or merely negligent/inadvertent?), and (4) mitigation factors supporting a lesser remedy than revocation (modification rather than revocation, additional conditions rather than revocation, partial detention rather than full custody). Defense at the forfeiture proceeding focuses on (1) the nonappearance / violation predicate, (2) the Art. 22.13 defenses, and (3) remittitur — the procedure under Art. 22.16 by which the court can reduce the forfeiture amount even after final judgment on a showing that the defendant has been returned to custody and the underlying criminal case has been resolved.

New criminal offenses committed during pretrial release are particularly damaging. A new offense is a condition violation (release conditions typically include "commit no further offense") and an Art. 17.40 ground for revocation; it is also a fact-pattern that supplies its own bond consideration in the new case under Art. 17.15 (the defendant's record of prior bond compliance is a statutory factor in the new bond amount). Counsel coordinates defense of the new case with revocation defense in the existing case — the two procedures share evidence, share witnesses, and share strategic considerations that no single-case defense plan can adequately address.

What to do after bond conditions are imposed

The first 30 days after bond conditions are imposed are decisive. Engage counsel immediately, comply absolutely with every condition, document every compliance step, surrender firearms if required, attend every appointment, and begin building the record for a motion to modify under Art. 17.40(b).

First, comply with every condition absolutely. Even where a condition is clearly excessive and a motion to modify is planned, comply pending the motion. Violation generates revocation exposure under Art. 17.40, forfeiture exposure under Art. 22, and (in family-violence cases) a separate criminal charge under PC § 25.07. The cost-benefit of "challenging by non-compliance" is never favorable — counsel modifies through formal motion practice, not through unilateral non-compliance. Read the bond paperwork carefully; if any condition is unclear, contact counsel for clarification before assuming you understand what is required.

Second, surrender any firearms if required. In any family-violence, stalking, or sexual-assault case where Art. 17.292 EPO terms attach, firearm possession is prohibited for the order's pendency. Surrender all firearms to a non-prohibited third party — a non-resident family member, a friend, or a licensed FFL holder for storage. Document the transfer: written receipt, photograph of the items, and confirmation of the non-prohibited status of the recipient. Possession during the EPO is a separate Texas crime under PC § 46.04(c). For DWI bonds with interlock requirements, install the device promptly at a court-approved vendor and maintain the monthly service.

Third, document compliance comprehensively. For drug-testing conditions, save every test result and every appointment receipt; build a record of clean tests over time. For GPS or home-confinement conditions, save records of approved exceptions (work, court, medical, education) and confirm the schedule with the monitoring vendor in writing. For curfew or stay-away conditions, save records of where you were and what you were doing during the relevant periods; mobile-phone location history, work time-cards, security camera footage, and witness statements all support compliance documentation. For employment and residence verification conditions, save proof of address, paystubs, and employer letters confirming the work schedule.

Fourth, attend every court appearance and every pretrial-services appointment. Nonappearance is the most serious violation — it triggers immediate bond forfeiture under Art. 22.02 (judgment nisi) and an arrest warrant under Art. 17.41 (capias). If a genuine emergency prevents appearance (medical, family, transportation failure), contact counsel immediately so a continuance motion can be filed before the setting. After-the-fact explanation is much weaker than before-the-fact notice and continuance.

Fifth, begin building the record for a motion to modify. Track compliance milestones — 30 days clean tests, 60 days of stable employment, 90 days of voluntary counseling completion, signed lease establishing stable residence. Every milestone supports a future motion to modify a specific condition. Counsel typically files an initial modification motion at 60-90 days post-bond to address the most burdensome condition, followed by subsequent motions as compliance milestones accumulate. The cumulative effect over the pretrial period can substantially reduce the daily burden of the conditions.

Sixth, plan for the trial-disposition transition. Bond conditions terminate at disposition — they are pretrial-release conditions, not post-conviction conditions. On disposition (whether by plea, trial verdict, or dismissal), the conditions either dissolve (dismissal/acquittal/probation-with-different-conditions) or transition to community-supervision conditions (if probation is imposed). Counsel coordinates the transition at sentencing — many of the same conditions (drug testing, no-contact, interlock for DWI cases) carry over to community supervision but with modified terms and durations. Sentencing-stage advocacy on conditions is a distinct strategic moment from the original pretrial bond-conditions setting.

DFW context and cost expectations

Each DFW county runs its bond-conditions system differently — Collin and Tarrant default to strict conditions; Dallas and Denton more flexible on modification. Defense fees for condition-modification motions range $1,500-$5,000+, with contested hearings at the high end and offense-specific condition packages varying by case type.

Collin County's bond-conditions practice is among the strictest in DFW. The Collin County District Attorney's office routinely advocates for full condition packages at magistration — including GPS in family-violence cases, full Art. 17.441 interlock terms in DWI cases, drug-testing in any case with substance-abuse nexus, and stay-away orders in any case with a complainant. The Collin County Criminal District Courts (366th, 416th, 380th, 470th) and county courts at law tend to grant condition modifications only after sustained compliance evidence — typically 90-180 days of clean compliance before relief on burdensome conditions. The Collin County Pretrial Services Department supervises personal-bond defendants; supervision fees run $40-$60/month. Counsel's first move on Collin County bonds is often a substantive personal-bond application with structured conditions rather than cash-bond with court-imposed conditions.

Denton County's bond-conditions practice is more flexible on modification than Collin. The Denton County Criminal District Attorney's office is willing to negotiate condition modifications where the defendant has demonstrated compliance, and Denton judges apply the Art. 17.40 reasonableness test with genuine attention to whether the condition continues to serve the statutory purpose. The 211th, 367th, 393rd, and 431st District Courts handle felony bond matters; the county courts at law handle misdemeanors. Denton County Pretrial Services supervises personal-bond defendants and operates a moderate-supervision posture. Mental-health diversion conditions for defendants with documented mental-health needs are available and reduce the standard condition burden.

Dallas County's bond-conditions practice is the most defense-friendly of the four DFW counties on modification. The Dallas County Criminal District Attorney's office negotiates condition modifications with greater willingness than Collin or Tarrant, and Dallas judges (in the Frank Crowley Courts Building Criminal Justice Center) apply the reasonableness analysis rigorously. The Dallas County Pretrial Services Department operates one of the largest pretrial-services agencies in Texas, with substantial personal-bond capacity and structured supervision options. Specialty courts under Tex. Gov't Code Chapter 124 (Drug Court, Mental Health Court, Veterans Court) operate condition modifications as part of diversion-track participation. The DFW domestic-violence advocacy ecosystem (Genesis Women's Shelter, The Family Place, Hope's Door New Beginning Center) participates in family-violence bond matters and influences condition packages in EPO cases.

Tarrant County's bond-conditions practice runs case-by-case depending on the assigned judge and the underlying offense. The Tarrant County Criminal District Attorney's office tends toward stricter condition packages similar to Collin County, particularly in family-violence and DWI cases. The Tim Curry Justice Center houses the Criminal District Courts (Criminal District Courts Nos. 1-4 and the District Courts) handling felony bond matters. Tarrant County Pretrial Services supervises personal-bond defendants. Modification motions filed with substantive compliance records receive serious consideration; templated motions filed without compliance documentation rarely succeed.

Defense fees for bond-condition modification motions vary by complexity. A straightforward motion-to-modify a single condition (e.g., drug-testing frequency, curfew, travel restriction) runs $1,500-$3,500 flat-fee for the motion-and-hearing package. Where a contested hearing is required — particularly where the State opposes modification or where the modification involves a no-contact or stay-away condition with complainant input — fees run $2,500-$5,000. Bond-revocation defense is more expensive: $3,500-$8,000 for a straightforward revocation hearing, $8,000-$15,000+ where the revocation is based on a new criminal offense and parallel defense of the new case is required. Bond-forfeiture defense under Chapter 22 typically runs $2,500-$7,500 for the surety-side defense; the defendant's exposure to forfeiture is less direct but counsel coordinates the Art. 22.13 defenses and Art. 22.16 remittitur procedure.

Typical bond-condition packages in DFW by offense type: DWI bonds — ignition interlock (mandatory under Art. 17.441 for second-DWI; common for first-DWI with aggravators), alcohol testing through SCRAM (Secure Continuous Remote Alcohol Monitor) or daily breath testing, no-driving without interlock-equipped vehicle, alcohol-education or evaluation requirement. Family-violence bonds — no-contact with complainant under Art. 17.292 EPO, stay-away from residence/workplace/school, firearm surrender, GPS monitoring in serious-injury cases, BIPP (Battering Intervention and Prevention Program) referral in some configurations. Drug-charge bonds — drug testing under Art. 17.49, treatment referral, no-contact with co-defendants, no presence at known drug locations, travel restriction to county or state. Theft-charge bonds — restitution as a condition where feasible, no-contact with victim/business, no presence at the location, employment verification. Sexual-assault bonds — no-contact with complainant, stay-away from the complainant's residence and workplace, GPS monitoring, internet-use restrictions in some configurations, registration-related conditions.

Timeline expectations: motion-to-modify hearings are typically scheduled within 14-30 days of filing, depending on docket congestion. Revocation hearings are scheduled within 7-14 days of motion. Forfeiture proceedings under Chapter 22 run on their own track and can extend 6-18 months after the underlying criminal case resolves. EPO modification hearings under Art. 17.292(j) are scheduled within 14-21 days of issuance. Counsel's first 30 days post-bond are spent (1) confirming compliance with every imposed condition, (2) documenting compliance for future motions, (3) coordinating EPO/firearm-surrender logistics in family-violence cases, (4) interfacing with pretrial-services for supervised defendants, and (5) drafting the initial motion-to-modify on the most burdensome conditions for filing at 60-90 days post-bond.