Memo Endorsement 25 Letter Motion Mr. Ilori seeks — USA v. Chancy et al. (Dkt. 26, S.D.N.Y.)

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U.S. District Court for the Southern District of New York · No. 1:20-cr-00378-LJL · Doc. 25 · 2020-07-31 · Docket on CourtListener

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Simpson Thacher & Bartlett LLP
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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 ECF 
July 31, 2020 
The Honorable Lewis J. Liman 
United States District Judge 
Southern District of New York 
500 Pearl St. 
New York, NY 10007 
Re:
United States v. Chancy, et al., 20 Cr. 00378 (S.D.N.Y.)
Dear Judge Liman: 
I represent Defendant Adedayo Ilori in the above-captioned action.  This letter is to 
request a modification of Mr. Ilori’s conditions of release, with the consent of the 
Government and Pre-Trial Services.  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 Mr. Ilori’s 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.  Further, on June 23, 2020, 
this Court, with the consent of the Government, approved a modification to the conditions of 
Mr. Ilori’s release to allow him to attend his daughter’s graduation on June 25, 2020. 
Mr. Ilori seeks to modify the conditions of his release to (i) add an additional 
financially responsible person as a co-signer on his Appearance Bond and (ii) modify his 
home detention condition to a nightly curfew with electronic monitoring1 so that he may help 
care for his family, assist in the responsibilities of his home, and perform physical exercise, as 
recommended by his doctor.  Pretrial Services has advised us that it would be a violation of 
1
If the present modification does not entirely alleviate Mr. Ilori’s present challenges, he  
reserves his rights to seek a further modification at a later date to remove the 
electronic monitoring. 
Case 1:20-cr-00378-LJL   Document 25   Filed 07/31/20   Page 1 of 3
GRANTED.  The Court grants the 
request that Mr. Ilori's conditions of 
release be modified according to the 
conditions set forth in this letter. 
7/31/2020
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Simpson Thacher & Bartlett LLP
July 31, 2020 
The Honorable Lewis J. Liman 
2 
the conditions of his release as they currently stand for him to pursue his career as a private 
personal trainer or to perform yard work or undertake routine household chores such as 
grocery shopping.  Mr. Ilori remains in touch with his personal training clients, and would be 
able to return to work promptly after the home detention condition is removed.  The current 
restrictions—especially Mr. Ilori’s inability to pursue his career—have strained his family, 
which is already going through a difficult time due to stress and financial difficulties caused 
by COVID-19. 
Modification is appropriate because (i) the addition of a second financially responsible 
person as a cosigner on his Appearance Bond will ensure Mr. Ilori’s compliance with his 
conditions of release; (ii) the facts show that Mr. Ilori is neither a flight risk nor a danger to 
the community, and (iii) a nightly curfew presents the least restrictive condition that would 
reasonably assure Mr. Ilori’s presence in court and would ensure the safety of the 
community, while also allowing him to care for his family in these difficult times.   
First, Mr. Ilori seeks to add Mr. Deyal Roopnarine as a co-signer to his Appearance 
Bond who, along with Mr. Ilori’s wife, Wunmi, will be the second financially responsible co-
signer.  Mr. Roopnarine is an employee of Envoy Air, Inc., where he receives a yearly salary 
of approximately $40,000.  Mr. Roopnarine lives in Brooklyn, NY, and is a close friend of 
Mr. Ilori’s who will be able to provide moral suasion to ensure Mr. Ilori complies with his 
conditions of release.  Mr. Roopnarine was interviewed yesterday by the Government, and 
has been approved as an additional co-signer. 
Second, with respect to flight risk, Mr. Ilori has demonstrated every intention of 
remaining in the jurisdiction and returning to court, and he intends to fight the charges 
against him.  From the first day he was charged, Mr. Ilori has complied with law 
enforcement, as demonstrated by the fact that he did not resist at the time of his arrest and 
has remained in faithful compliance with the conditions of his release to date, despite their 
currently restrictive nature that has prevented him from pursuing his career or helping his 
family with household chores.  Additionally, Mr. Ilori’s family resides in this district and he 
has no significant ties outside of the district that would present a risk of flight.  Finally, Mr. 
Ilori’s wife remains subject to the $100,000 Appearance Bond—as does Mr. Ilori himself, 
and, if this request is granted, Mr. Roopnarine—which will ensure Mr. Ilori’s appearance at 
future court dates.   
Third, as to the safety of the community, Mr. Ilori does not pose a threat to the 
community as evidenced by the fact that he does not have a record of violent crime, nor has 
he demonstrated any such behavior since his arrest.   
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Simpson Thacher & Bartlett LLP
July 31, 2020 
The Honorable Lewis J. Liman 
3 
Finally, neither of Mr. Ilori’s co-defendants are subject to any location restriction 
programs or location monitoring.  See Dkt. No. 5 at 4 (Herode Chancy’s Appearance Bond, 
noting no location restriction programs), Dkt. No. 9 at 4 (Michael Albarella’s Appearance 
Bond, noting no location restriction programs).  If this request is granted, Mr. Ilori will still 
be subject to a nightly curfew, which will be more restrictive than the conditions imposed on 
either of his co-defendants.  
In light of the foregoing, modifying Mr. Ilori’s conditions of release to remove the 
home detention order and replace it with a nightly curfew would present the least restrictive 
condition that would reasonably assure the appearance of Mr. Ilori and the safety of his 
community.   
We have spoken with AUSAs Cecilia E. Vogel and Tara M. La Morte, and Mr. Ilori’s 
pre-trial officer, and they consent to the request, with the condition that Mr. Ilori’s home 
detention condition remain in effect until such time as Mr. Roopnarine signs the Appearance 
Bond, after which time the home detention with electronic monitoring condition should be 
removed and replaced with the nightly curfew with electronic monitoring condition. 
Thank you for your consideration. 
Respectfully submitted, 
/s/ Brooke Cucinella
Brooke Cucinella 
cc: 
Counsel of record (by ECF) 
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