Motion to Modify Conditions of Release to Allow International Trip — USA v. Ebrahimzadeh (Dkt. 19, D. Mass.)

Record facts

U.S. District Court for the District of Massachusetts · No. 1:25-cr-10455-RGS · Doc. 19 · 2025-12-19 · Docket on CourtListener

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UNITED STATES DISTRICT COURT 
DISTRICT OF MASSACHUSETTS 
UNITED STATES OF AMERICA, 
v. 
DAVID EBRAHIMZADEH, 
Defendant. 
No. 1:25-cr-10455 
 
 
MOTION REQUESTING PERMISSION TO TRAVEL 
OUTSIDE THE UNITED STATES 
 
Pursuant to his conditions of release, Defendant David Ebrahimzadeh seeks the Court’s 
permission to attend a family vacation in Aguilla from December 28, 2025 to January 3, 2026. In 
support of this motion, undersigned counsel states as follows:  
1. Mr. Ebrahimzadeh has had a vacation to Aguilla booked since at least October 2025, 
when he made a hotel reservation. He is traveling with his wife and three children and 
has booked roundtrip airfare. 
2. Mr. Ebrahimzadeh has known about this investigation for multiple years and traveled 
internationally during that time, always returning. 
3. Mr. Ebrahimzadeh was born in the United States, has citizenship in no other country, 
and has substantial business interests here. His entire immediate family resides in the 
United States. 
4. Mr. Ebrahimzadeh’s counsel provided his itinerary to the government and probation, 
as instructed by the Court. 
Case 1:25-cr-10455-RGS     Document 19     Filed 12/19/25     Page 1 of 3

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5. The government stated: “In your motion, please note the government’s objection to the 
travel outside the United States for the reasons that AUSA Basil stated on the record 
last week.” 
6. Probation stated: “I can confirm I have received Mr. Ebrahimzadeh’s itinerary for his 
trip to Aguilla. You may confirm in your motion that I have received it. Please forward 
to me the court order with the approval of travel when it is available.” 
Additionally, the United States District Court Pretrial Services Office for the Southern 
District of New York has indicated that they are closed December 25 and 26. Further, January 4—
the day after Mr. Ebrahimzadeh returns—is a Sunday. Therefore, Mr. Ebrahimzadeh respectfully 
requests the Court grant him permission to pick up his passport on or after December 23, 2025 and 
return it on or before January 5, 2026. 
 
Dated: December 19, 2025 
 
 
Respectfully submitted, 
 
/s/ R. Scott Seitz      
Robert A. Fisher (BBO No. 652602) 
R. Scott Seitz (BBO No. 696658) 
Jacob E. Morse (BBO No. 709512) 
NIXON PEABODY LLP 
53 State Street 
Boston, MA 02109 
Tel.: (617) 345-1000 
Fax:  (855) 345-1300 
rfisher@nixonpeabody.com 
sseitz@nixonpeabody.com 
jmorse@nixonpeabody.com 
 
 
 
 
 
 
 
Case 1:25-cr-10455-RGS     Document 19     Filed 12/19/25     Page 2 of 3

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CERTIFICATE OF SERVICE 
 
I hereby certify that the foregoing document was filed electronically on December 19, 
2025 and thereby delivered by electronic means to all registered participants as identified on the 
Notice of Electronic Filing (“NEF”).   
 
/s/ R. Scott Seitz       
R. Scott Seitz 
 
 
 
Case 1:25-cr-10455-RGS     Document 19     Filed 12/19/25     Page 3 of 3

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