FILING ERROR - ELECTRONIC FILING IN NON-ECF CASE - LETTER MOTION addressed to… — USA v. Chancy et al (Dkt. 14)

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A letter motion dated March 11, 2020, Document 14 filed 03/11/20 under Case 1:20-cr-00378-LJL, from Brooke E. Cucinella of Simpson Thacher & Bartlett LLP to the Honorable Ona T. Wang, United States Magistrate Judge, in United States v. Ilori, No. 20 Mag. 2482 (S.D.N.Y.). Counsel for Adedayo Ilori ask, with the Government's consent, to modify conditions of release so that the $100,000.00 Appearance Bond secured on March 4, 2020 may be co-signed by only one financially responsible person, Mr. Ilori's wife. The letter states that Mr. Ilori was arrested in connection with bank fraud allegations and is subject to home detention secured by electronic monitoring. It adds that the Assistant U.S. Attorneys and the Pretrial Services Officer do not object and that Mr. Ilori reserves the right to seek further revision.

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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-cr-00378-LJL     Document 14     Filed 03/11/20     Page 1 of 1

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