Letter to Judge Cave, Request to Modify Conditions of Release — United States v. Chanette Lewis (Document 23)

Summary

This is a letter dated November 4, 2021, to Magistrate Judge Sarah L. Cave in United States v. Chanette Lewis, signed /s/ Mark Gombiner, attorney for Chanette Lewis. It asks the Court to modify Ms. Lewis's conditions of release to allow travel to the Southern District of Florida, and says it is made with the consent of Pre-trial Services and no objection from the Government. Ms. Lewis wishes to travel to Orlando, Florida from November 26, 2021 to November 30, 2021, accompanied by her son, husband, and cousin, and will attend her mental health treatment sessions as scheduled on November 25, 2021 and December 2, 2021. The letter recalls that on October 5, 2021, Magistrate Judge Parker set conditions that include a $200,000 personal recognizance bond and travel limited to SDNY/EDNY.

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November 4, 2021 
 
BY EMAIL  
The Honorable Sarah L. Cave  
United States Magistrate Judge 
Daniel Patrick Moynihan 
United States Courthouse 
500 Pearl St. 
New York, NY 10007 
Email: Cave_NYSDChambers@nysd.uscourts.gov  
 
 
 
 
Re: 
United States v. Chanette Lewis 
 
21 Mj. 9354 (UA) 
 
Dear Judge Cave: 
 
 
I write with the consent of Pre-trial Services (PTS) and no objection from the 
Government to respectfully request that the Court modify Ms. Lewis’s conditions of release to 
allow her to travel to the Southern District of Florida. Ms. Lewis wishes to travel to Orlando, 
Florida to celebrate her son’s eleventh birthday from November 26, 2021 to November 30, 
2021. She would be accompanied by her son, husband, and cousin. We have been in touch 
with PTS and will provide them the exact address, travel itinerary, and any other requested 
information. Ms. Lewis will attend her mental health treatment sessions as scheduled on 
November 25, 2021 and December 2, 2021  
 
On October 5, 2021, Magistrate Judge Parker set conditions of release including the 
following: a $200,000 personal recognizance bond to be signed by 2 FRP'S (Mother to sign 
for moral suasion), Travel Limited to SDNY/EDNY, Surrender Travel Documents (& No 
New Applications); pretrial supervision as directed by Pretrial Services; Deft to Continue or 
Seek Employment. The conditions also include no contact with co-defendants outside 
presence of counsel; deft may not possess personal identifying information of others (except 
her children); or create any fraudulent documents; deft shall not open any new financial, 
business, or personal bank accounts, debit or credit card accounts, lines of credit, or loans 
without prior approval from PTS. On October 14, 2021, Judge Netburn added a mental health 
condition so that Pretrial Services could more fully work with Ms. Lewis on her care plan.  
 
Thank you for your time and consideration.  
 
 
Case 1:21-cr-00729-LAK     Document 23     Filed 11/05/21     Page 1 of 2

 
Re: 
United States v. Chanette Lewis 
 
21 Mj. 9354 
 
Respectfully submitted, 
 
 
 
 
 
 
 
 
/s/Mark Gombiner 
Mark Gombiner 
Attorney for Chanette Lewis 
(212) 417-8718 
 
 
 
cc: 
AUSA Michael Daniel Neff 
USPTSO Karina Chin Vilefort  
 
 
 
 
SO ORDERED: 
 
 
 
 
______________________________ 
HONORABLE SARAH L. CAVE   
United States Magistrate Judge 
 
 
 
 
 
 
11/5/2021
Case 1:21-cr-00729-LAK     Document 23     Filed 11/05/21     Page 2 of 2

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