Letter Motion: Modification to the Conditions of Mr. Ilori's Release — United States v. Ilori (Doc. 14)

Summary

A letter motion dated March 11, 2020 from Brooke E. Cucinella of Simpson Thacher & Bartlett LLP, counsel for Adedayo Ilori, to Magistrate Judge Ona T. Wang in United States v. Ilori, No. 20 Mag. 2482, in the U.S. District Court for the Southern District of New York, filed as Document 14 in Case 1:20-mj-02482-UA. The letter states that Ilori was arrested on March 4, 2020 in connection with bank fraud allegations and released on a $100,000.00 Appearance Bond secured by two financially responsible persons, with home detention and electronic monitoring. It asks, with the government's consent, that the bond may be co-signed by only one financially responsible person, Wunmi Ilori. The letter says Assistant U.S. Attorneys Cecilia Vogel and Tara LaMorte consent and Pretrial Services Officer Josh Rothman does not object.

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Simpson Thacher & Bartlett LLP
425 LEXINGTON AVENUE
NEW YORK, NY 10017-3954 
TELEPHONE: +1-212-455-2000
FACSIMILE: +1-212-455-2502 
Direct Dial Number 
+1-212-455-3070 
E-mail Address 
brooke.cucinella@stblaw.com 
BY ECF 
March 11, 2020 
Re: 
United States v. Ilori, No. 20 Mag. 2482 (S.D.N.Y.) 
The Honorable Ona T. Wang
United States Magistrate Judge 
Southern District of New York  
500 Pearl Street 
New York, NY 10007
Dear Judge Wang: 
We represent Adedayo Ilori in the above-captioned matter and write, with the consent 
and agreement of the Government, to seek a modification to the conditions of Mr. Ilori’s release.   
On March 4, 2020, Mr. Ilori was arrested in connection with bank fraud allegations, and 
ordered to be released on a $100,000.00 Appearance Bond secured by two financially 
responsible persons.  Among other conditions of his release, Mr. Ilori is subject to home 
detention secured by electronic monitoring and is under supervision by the Pretrial Services 
Office of the Southern District of New York. 
We write to respectfully request that Mr. Ilori’s conditions of release be altered such that 
his Appearance Bond may be co-signed by only one financially responsible person, Mr. Ilori’s 
wife and mother of his children, Wunmi Ilori.  Mrs. Ilori is scheduled to be interviewed by the 
United States Attorney’s Office this afternoon and we anticipate that she will be approved as the 
sole co-signer of Mr. Ilori’s Appearance Bond.  Further, as noted above, we have spoken with 
Assistant U.S. Attorneys Cecilia Vogel and Tara LaMorte, who consent to this request, as well as 
with Pretrial Services Officer Josh Rothman, who also does not object to this request. 
Mr. Ilori reserves his rights to seek a further revision of his conditions of release at a later 
date. 
Respectfully submitted, 
/s/ Brooke E. Cucinella
Brooke E. Cucinella 
cc: 
Counsel of Record (by ECF) 
Case 1:20-mj-02482-UA     Document 14     Filed 03/11/20     Page 1 of 1

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