FILING ERROR - ELECTRONIC FILING IN NON-ECF CASE - LETTER MOTION addressed to… — USA v. Chancy, et al (Dkt. 19)

Summary

A letter motion dated June 23, 2020, Document 19, filed 06/23/20 in United States v. Ilori, 20 Mag. 2482 (S.D.N.Y.), from Brooke Cucinella of Simpson Thacher & Bartlett LLP to Judge Ona T. Wang. Counsel for Defendant Adedayo Ilori writes, with the consent of the Government and Pre-Trial Services, to request a modification of conditions of release. The letter recites that on March 4, 2020 Mr. Ilori was ordered released on a $100,000 Appearance Bond and that on March 11, 2020, the Court approved a modification allowing one co-signer. It asks that the conditions be altered to allow attendance at a school event on Thursday, June 25, beginning at 10 am, with monitoring throughout and check-ins with the Pretrial Officer, and states that Assistant U.S. Attorneys Cecilia Vogel and Tara LaMorte consent.

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Simpson Thacher & Bartlett LLP 
425 LEX INGTON AVENUE
NEW YORK, NY 10017-3954 
 
TELEP HONE: +1-212-455-2000 
FACSIMILE: +1-212-455-2502 
Direct Dial Number 
+1-212-455-3070 
 
E-mail Address 
Brooke.Cucinella@stblaw.com 
 
B E I J I N G
H O N G  K O N G
H O U S T O N
L O N DO N
L O S  A N G E L E S  
P A L O  A L T O  
S Ã O  P A U L O
S E O U L
T O K Y O  
W A S H I N G T O N , D . C .  
 
BY EMAIL 
June 23, 2020  
The Honorable Ona T. Wang  
United States District Judge 
Southern District of New York 
500 Pearl St. 
New York, NY 10007 
Re: 
United States v. Ilori, 20 Mag. 2482 (S.D.N.Y.) 
 
Dear Judge Wang : 
We represent Defendant Adedayo Ilori in the above-captioned case.  We write to 
request, with the consent of the Government and Pre-Trial Services, a modification of Mr. 
Ilori’s conditions of release.  On March 4, 2020, Mr. Ilori was ordered released on a 
$100,000 Appearance Bond secured by two financially responsible persons.  Among other 
conditions of his release, Mr. Ilori is subject to home confinement secured by electronic 
monitoring and is under supervision by the Pretrial Services Office of the Southern District of 
New York.  On March 11, 2020, this Court, with the consent of the Government, approved a 
modification to the conditions of his release such that his Appearance Bond could be co-
signed by only one financially responsible person.   Wunmi Ilori, Mr. Ilori’s wife, was 
approved as the sole co-signer of Mr. Ilori’s Appearance Bond.  
 
 
 
We respectfully request that Mr. Ilori’s conditions of release be altered to allow his 
attendance at his daughter’s graduation on Thursday, June 25, beginning at 10 am, at PS232 
Walter Ward School, 153-23 83rd St, in Howard Beach, New York.  The school is taking 
special Covid-related precautions, including inviting one family at a time in to the auditorium 
to celebrate each individual graduate.  His attendance at this meaningful event is at the 
request of (and of utmost importance to) his daughter.  Mr. Ilori will be under monitoring 
throughout the event and will check in with his Pretrial Officer before he leaves for the event 
and after he returns home.  We have conferred with his Pretrial Officer, Joshua Rothman, as 
well as Assistant U.S. Attorneys Cecilia Vogel and Tara LaMorte, who have advised that they 
consent to Mr. Ilori’s attendance at his daughter’s graduation.   
 
Thank you for your consideration. 
Case 1:20-mj-02482-UA     Document 19     Filed 06/23/20     Page 1 of 2

Simpson Thacher & Bartlett LLP
June 23, 2020 
The Honorable Ona T. Wang  
 
2 
 
 
 
 
 
 
 
 
 
 
Respectfully submitted, 
 
/s/ Brooke Cucinella 
 
 
 
 
 
 
 
 
Brooke Cucinella 
 
 
 
 
 
 
 
 
 
cc: 
AUSA Cecilia E. Vogel 
 
AUSA Tara M. LaMorte 
Case 1:20-mj-02482-UA     Document 19     Filed 06/23/20     Page 2 of 2

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