Motion Requesting Access to Passport for Travel Within the United States — United States v. Ebrahimzadeh

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A motion by defendant David Ebrahimzadeh in United States of America v. David Ebrahimzadeh, No. 1:25-cr-10455-RGS, U.S. District Court for the District of Massachusetts, filed January 8, 2026 as Document 25, requests access to his passport for travel within the United States and to obtain a Social Security card. It asks to obtain the passport from the Pretrial Services Office for the Southern District of New York from January 9, 2026 to January 16, 2026, for travel to West Palm Beach, Florida and a Social Security card appointment, and for a future 48-hour period within 30 days to obtain a REAL ID. The motion states that neither the Government nor Pretrial Services objects. It is dated January 7, 2026 and signed /s/ by R. Scott Seitz; the first page prints the name David H. Hennessy beside Jan 8, 2026.

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Case 1:25-cr-10455-RGS Document 25 Filed 01/08/26 Page1of4

UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS

UNITED STATES OF AMERICA,

Vv.

No. 1:25-cr-10455
DAVID EBRAHIMZADEH,

Defendant. (A David H. Hennessy |

Jan 8, 2026

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 25 Filed 01/08/26 Page 2of4

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 (1)
from January 9, 2026 to January 16, 2026, for a one-day domestic trip and to obtain his
Social Security card; and (11) 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.
Case 1:25-cr-10455-RGS Document 25 Filed 01/08/26 Page 3of4

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
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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