ENDORSED LETTER as to Adedayo Ilori addressed to Magistrate Judge Ona T.… — USA v. Chancy et al (Dkt. 15)

Summary

A letter dated March 11, 2020 from counsel at 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.), filed as Document 14 in docket No. 1:20-mj-02482-UA (footer: Case 1:20-cr-00378-LJL, Document 15). Counsel for Adedayo Ilori state that they write with the consent and agreement of the Government to seek a modification of the conditions of release. They state that Ilori was arrested on March 4, 2020 and ordered released on a $100,000.00 Appearance Bond secured by two financially responsible persons, and ask that the bond be co-signed by only one financially responsible person. The letter says that Assistant U.S. Attorneys Cecilia Vogel and Tara LaMorte consent and that a Pretrial Services Officer does not object. The signature line reads /s/ Brooke E. Cucinella.

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Case 1:20-mj-02482-UA Document 14 Filed 03/11/20 Page 1 of 1 
Simpson Thacher & Bartlett LLP 
Direct Dial Number 
+1-212-455- 3070 
BYECF 
425 LEXINGTON AVENUE 
NEW YORK, NY 10017- 3954 
TELEPHONE: + 1-212-455-2000 
FACSIMILE: +1-212-455-2502 
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: 
E-mail Address 
brooke.cucinella @stbla w .com 
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 ofNew York. 
We write to respectfully request that Mr. Ilori's conditions of release be altered such that ao1)1Jvid . 
his A 
earance Bond ma be co-si 
ed b onl one financially responsible person, Mr. Ilori's -r ~ I 
wife and mother of his children, Wunmi Ilori. Mrs. Ilon rs sc e u e 
o em e7vrewed by the 
Ofl,J 
ti• 
United States Attorney's Office this afternoon and we anticipate that she will be approved as the 
3· ;I 
sole co-sigrrer 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. 
cc: 
Counsel of Record (by ECF) 
Respectfully submitted, 
Isl Brooke E. Cucinella 
Brooke E. Cucinella 
~~d. 
,,~ aoao 
Case 1:20-cr-00378-LJL     Document 15     Filed 03/11/20     Page 1 of 1

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