Court filing

United States v. Rafael Martinez — Letter to Court re Travel (ECF 26) (S.D.N.Y.)

Summary

Letter of July 12, 2022 from Morvillo Abramowitz Grand Iason & Anello to Judge Liman in United States versus Rafael Martinez, 22 Cr. 251 (LJL), Southern District of New York, filed as Document 26 and endorsed "REQUEST GRANTED" on 7/13/2022. Counsel ask permission for Rafael Martinez to travel outside the bail limits to California for several days to participate in the Stanford University executive program, departing Newark on July 15, 2022 and returning July 19. The letter states that participation was approved in November 2021 and the trip was booked in advance of the arrest. It reports that Pretrial Services had no objection and that the government takes no position.

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Filed July 12, 2022 in 006 ECF 26 Gov Uscourts; one of 58 filings from this case.

Record facts

Court	U.S. District Court for the Southern District of New York
Filed	2022-07-12

Cite this document

“United States v. Rafael Martinez — Letter to Court re Travel (ECF 26) (S.D.N.Y.).” U.S. District Court for the Southern District of New York, No. 1:22-cr-00251-LJL, Doc. 25, filed 2022-07-12. Archived at Pandemic Darlings, https://pandemicdarlings.com/court-filings/full-docket-006-ecf-26-gov-uscourts-nysd-579149-26-0-pdf/2026-05-16-006-ecf-26-gov-uscourts-nysd-579149-26-0-006-ecf-26-gov-uscourts-nysd-579149-26-0/, SHA-256 3c392a32e6b0e46b9316bef63435f41996b46d0ad7b7c37f6bf2c80bbfa0b7ef.

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Case 1:22-cr-00251-LJL Document 26 Filed 07/12/22 Page 1 of 2

ELKAN ABRAMOWITZ
RICHARD F. ALBERT
ROBERT J. ANELLO*
KATHLEEN E. CASSIDY
BENJAMIN S. FISCHER
CATHERINE M. FOTI
CHRISTOPHER B. HARWOOD
LAWRENCE IASON

BRIAN A. JACOBS
TELEMACHUS P. KASULIS
KAREN R. KING

ROBERT M. RADICK*
JONATHAN S. SACK**
EDWARD M. SPIRO
JEREMY H. TEMKIN
RICHARD D. WEINBERG

MORVILLO ABRAMOWITZ GRAND IASON & ANELLOP.C.

565 FIFTH AVENUE SENIOR COUNSEL
NEW YORK, NEW YORK IOOI7 PAUL R. GRANO
(212) 856-9600 COUNSEL

FAX: (2l2) 856-9494 JASMINE JUTEAU
CURTIS B. LEITNER

www.maglaw.com ROBERT G. MORVILLO

1938-201!

MICHAEL C. SILBERBERG
1940-2002

JOHN J. TIGUE, JR
1939-2009

WRITER'S CONTACT INFORMATION

tkasulis@maglaw.com
(212) 880-9555

*ALSO ADMITTED IN WASHINGTON, 0.C

**ALSO AOMITTED IN CONNECTICUT

July 12, 2022

Hon. Lewis J. Liman REQUEST GRANTED. .
United States District Judge The Court approves the modification to Mr. Martinez's
Southern District of New York bail conditions to permit him to travel as proposed.

500 Pearl Street 7/13/2022 SOORDERED. yy,

New York, New York 10007 wi [ne

Re: United States v. Rafael Martinez, ~~ LEWAS J. LIMAN
22 Cr. 251 (LJL) United States District Judge

Dear Judge Liman,

We represent Rafael Martinez in the above-captioned case and seek the Court’s
permission for Mr. Martinez to travel on a brief trip outside the bail limits imposed by this Court.

Mr. Martinez has been at liberty since he was arrested on February 28, 2022 and
presented before Hon. Katherine H. Parker on March 1. Mr. Martinez’s bond currently permits
him to travel within the Southern and Eastern District of New York, the District of New Jersey,
the District of Connecticut, and the District of Massachusetts.

Mr. Martinez seeks to travel to California for several days to participate in the Stanford
University executive program. On July 15, 2022, he is scheduled to depart from Newark, New
Jersey at 6:30am and to arrive in San Francisco, California at 9:25am. He plans to stay at the
Fairmont hotel in San Francisco. He is scheduled to depart from San Francisco on July 18 at
9:00pm and to arrive in Newark on July 19 at 5:15am. Mr. Martinez’s participation in the
program was approved in November 2021 and this trip was booked in advance of Mr. Martinez’s
arrest in this case.

On June 30, 2022, we advised Mr. Martinez’s Pretrial Services Officer and the assigned
Assistant United States Attorney of this proposed travel. On July 11, Pretrial Services indicated
Case 1:22-cr-00251-LJL Document 26 Filed 07/12/22 Page 2 of 2

MORVILLO ABRAMOWITZ GRAND IASON & ANELLO PC.

Hon. Lewis J. Liman
P.2

that they had no objection to this application, and the government indicated that it takes no
position.

We thank the Court for its consideration of this matter.

Respectfully submitted,

MORVILLO ABRAMOWITZ GRAND IASON &
ANELLO, P.C.

/s/ Telemachus P. Kasulis
Telemachus P. Kasulis
Elkan Abramowitz

WILLKIE FARR & GALLAGHER LLP

Michael S. Schacter
Randall Jackson

Counsel for Rafael Martinez

ce: AUSA Micah Fergenson

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