Memo Endorsement granting 29 Letter Motion — USA v. Martinez (Dkt. 30, S.D.N.Y.)

Summary

Letter of September 28, 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, with an endorsement dated 9/29/2022 reading "REQUEST GRANTED" and granting permission for the travel in September and October 2022. Counsel sought permission for Rafael Martinez to travel to California from September 29, 2022 to continue the Stanford University executive program, returning to Newark on October 9, 2022. The letter also asks leave for travel to the next session on March 14, 2023 and other sessions scheduled in 2023. In the endorsement, the Court will consider future travel when and if there are future applications for a temporary modification of the bail conditions.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Record facts

Full text

Text recognized from a scanned document; may contain errors.

Case 1:22-cr-00251-LJL Document 20 Filed 09/28/22 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

565 FIFTH AVENUE

NEW YORK, NEW YORK |IOOI7

(212) 856-9600

FAX: (2l2e) 856-9494

www.maglaw.com

WRITER'S CONTACT INFORMATION

tkasulis@maglaw.com
(212) 880-9555

MORVILLO ABRAMOW!ITZ GRAND IASON & ANELLOP.C.

SENIOR COUNSEL
PAUL R. GRAND

COUNSEL
JASMINE JUTEAU
CURTIS B. LEITNER

ROBERT G. MORVILLO
1938-201)

MICHAEL C. SILBERBERG
1940-2002

JOHN J. TIGUE, JR
1939-2009

*ALSO ADMITTED IN WASHINGTON, D.C

**ALSO ADMITTED IN CONNECTICUT

September 28, 2022
REQUEST GRANTED.
Hon. Lewis J. Liman Permission granted for the travel in September and
United States District Judge October 2022. The Court will consider future travel
Southern District of New York when and if there are future applications for a temporary
500 Pearl Street modification of the defendant’s bail conditions.

New York, New York 10007
9/29/2022 SOORDERED. Wy
4

Re: United States v. Rafael Martinez, a / (i

22 Cr. 251 (LJL) LEWis J. LIMAN

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 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 Magistrate Judge 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.

In July 2022, Mr. Martinez received permission from the Court to travel to California in
connection with his participation in the Stanford University executive program. Mr. Martinez
again seeks permission from the Court to travel to California so that he may continue to
participate in that program.

Mr. Martinez intends to travel to California tomorrow, September 29, 2022. He is
scheduled to depart from Newark, New Jersey at 5:25 pm and to arrive in Los Angeles at 8:36
pm. He plans to stay at the Loews Santa Monica Beach Hotel. He will then drive from Los
Angeles to San Francisco, and he intends to stay in lodging en route for one night. When Mr.
Martinez arrives in San Francisco, he will stay at the Fairmont Hotel. He is scheduled to depart
from San Francisco on October 8, 2022 at 10:40 pm and to arrive in Newark on October 9, 2022
Case 1:22-cr-00251-LJL Document 20 Filed 09/28/22 Page 2 of 2

MORVILLO ABRAMOWITZ GRAND IASON & ANELLO PC.

Hon. Lewis J. Liman
P.2

at 7:00 am.' Mr. Martinez’s participation in the program was approved in November 2021, prior
to his arrest in this case.

Mr. Martinez also intends to travel to California periodically to continue his participation
in the Stanford University executive program. The next scheduled session is on March 14, 2023.
Mr. Martinez would request permission to travel to California in connection with that session
and any other sessions scheduled in 2023 that do not conflict with the proceedings in this case. If
the Court permits this travel, we will provide detailed trip information to the AUSA and Pretrial
Services Officer assigned to this matter.

Earlier today, we advised Mr. Martinez’s Pretrial Services Officer and the assigned
Assistant United States Attorney of this proposed travel. Pretrial Services indicated 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
U.S. Pretrial Services Officer Viosanny Harrison

' Stanford University’s executive program is also offering a secondary program that extends until
October 10, 2022. Mr. Martinez is awaiting notice of whether availability in that program will
open up. If it does, he would intend to participate in that program and return to New Jersey after
that program ends on October 10, 2022.


File and source

File

007_ECF_30_gov.uscourts.nysd.579149.30.0.pdf

Size

284,628 bytes

SHA-256

b065c31d6e9856c092711bb390f7db8695cb91a8a05cc2db0b5553065e4824d1

Our copy

007_ECF_30_gov.uscourts.nysd.579149.30.0.pdf

Original

storage.courtlistener.com