Motion to Modify Conditions of Release to Obtain Passport for Domestic Travel — USA v. Ebrahimzadeh (Dkt. 24, D. Mass.)

Record facts

U.S. District Court for the District of Massachusetts · No. 1:25-cr-10455-RGS · Doc. 24 · 2026-01-07 · Docket on CourtListener

Full text

UNITED STATES DISTRICT COURT 
DISTRICT OF MASSACHUSETTS 
UNITED STATES OF AMERICA, 
v. 
DAVID EBRAHIMZADEH, 
Defendant. 
 
No. 1:25-cr-10455 
 
 
MOTION REQUESTING ACCESS TO PASSPORT FOR TRAVEL  
WITHIN THE UNITED STATES AND TO OBTAIN A SOCIAL SECURITY CARD 
 
Pursuant to his conditions of release, Defendant David Ebrahimzadeh seeks the Court’s 
permission to obtain his passport from the United States District Court Pretrial Services Office for 
the Southern District of New York for a one-week period so that he may (i) travel to West Palm 
Beach, Florida from January 12, 2026 to January 13, 2026, and, (ii) so that he may use his passport 
to obtain an official copy of his Social Security card, which he will use to obtain a REAL ID. In 
support of this motion, undersigned counsel states as follows:  
1. Mr. Ebrahimzadeh does not currently hold a REAL ID and thus must use his passport 
for domestic travel purposes until he obtains a REAL ID. 
2. Mr. Ebrahimzadeh has known about this investigation for multiple years and traveled 
domestically and internationally during that time, always returning. 
3. With the Court’s permission, Mr. Ebrahimzadeh recently traveled to Anguilla with his 
family and returned without issue.  
4. 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. 
Case 1:25-cr-10455-RGS     Document 24     Filed 01/07/26     Page 1 of 4

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5. For his upcoming domestic travel, Mr. Ebrahimzadeh has already provided Pretrial 
Services with a copy of his travel itinerary and where he is staying, as required by his 
conditions of release.  See ECF No. 12. 
6. Further, to lessen the administrative burden on probation and the Court moving forward, 
Mr. Ebrahimzadeh is seeking a REAL ID. 
7. To obtain a REAL ID, Mr. Ebrahimzadeh must first obtain a copy of his Social Security 
card.  He has an appointment scheduled on January 16, 2026 for that purpose, and he 
will need his passport for that appointment.  
8. Additionally, Mr. Ebrahimzadeh will need his passport to obtain his REAL ID after he 
receives a copy of his Social Security card.   
9. To avoid the need to return to Court after Mr. Ebrahimzadeh receives his Social 
Security card, Mr. Ebrahimzadeh further requests that the Court permit him to, within 
30 days, obtain his passport for a 48-hour period for his REAL ID appointment, which 
he will schedule once he receives his Social Security card.  
10. In sum, Mr. Ebrahimzadeh requests that the Court permit him to obtain his passport (i) 
from January 9, 2026 to January 16, 2026, for a one-day domestic trip and to obtain his 
Social Security card; and (ii) for a future 48-hour period within 30 days so that he may 
obtain his REAL ID.   
11. Neither the Government nor Pretrial Services objects to the return of Mr. 
Ebrahimzadeh’s passport on these two occasions for these two purposes. 
Given the proximity of his upcoming travel, Mr. Ebrahimzadeh respectfully requests the 
Court grant him permission to pick up his passport on January 9, 2026 and return it on or before 
January 16, 2026. 
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Dated: January 7, 2026 
 
 
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 
Telephone: (617) 345-1000 
Facsimile:  (855) 345-1300 
Email:  rfisher@nixonpeabody.com 
Email:  sseitz@nixonpeabody.com 
Email:  jmorse@nixonpeabody.com 
 
 
 
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CERTIFICATE OF SERVICE 
 
I hereby certify that the foregoing document was filed electronically on January 7, 2026 
and thereby delivered by electronic means to all registered participants as identified on the Notice 
of Electronic Filing (“NEF”).   
 
/s/ Jacob E. Morse       
Jacob E. Morse 
 
 
 
 
 
CERTIFICATE OF CONSULTATION 
 
I hereby certify that, consistent with Local Rule 7.1(a)(2), the parties have conferred and 
attempted in good faith to resolve or narrow the issues presented in this motion.  The Government 
indicated that it does not object to this motion. 
 
/s/ R. Scott Seitz       
R. Scott Seitz 
 
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