Assented to Motion to Modify Conditions of Release to Obtain Passport — USA v. Ebrahimzadeh (Dkt. 37, D. Mass.)

Record facts

U.S. District Court for the District of Massachusetts · No. 1:25-cr-10455-RGS · Doc. 37 · 2026-02-26 · 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 
 
 
DEFENDANT’S ASSENTED TO MOTION REQUESTING ACCESS TO PASSPORT 
FOR DOMESTIC TRAVEL AND TO OBTAIN REAL ID 
 
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 so that he may (i) travel to Los Angeles, California with his 
family on March 5–9, 2026; (ii) travel to Austin, Texas on March 15–16, 2026; and (iii) for a future 
48-hour period so that he may obtain his 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. As discussed in prior orders, 
Mr. Ebrahimzadeh is seeking a REAL ID, which first required him to obtain a social 
security card and birth certificate. He has now completed those appointments and has 
those documents. 
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. 
Case 1:25-cr-10455-RGS     Document 37     Filed 02/26/26     Page 1 of 5

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4. This Court also recently permitted Mr. Ebrahimzadeh access to his passport for 
domestic travel.  See ECF No. 25. 
5. 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. 
6. For his upcoming domestic travel, Mr. Ebrahimzadeh has already provided Pretrial 
Services with copies of his travel itineraries and where he is staying, as required by his 
conditions of release.  See ECF No. 12. 
7. Further, to lessen the administrative burden on probation and the Court moving forward, 
Mr. Ebrahimzadeh is seeking a REAL ID, and therefore requests advance permission 
to access his passport for a future 48-hour period in order to finish the process of 
obtaining a REAL ID.  
8. Neither the Government nor Pretrial Services objects to the return of Mr. 
Ebrahimzadeh’s passport for his planned domestic travel or for purposes of obtaining 
his REAL ID. 
Accordingly, Mr. Ebrahimzadeh respectfully requests the Court grant him permission to 
obtain his passport for his domestic travel on March 5–9 and 15–16, 2026, and a future 48-hour 
period so that he may finish obtaining his REAL ID. 
 
 
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Dated: February 26, 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 February 26, 2026 
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 
 
 
 
 
 
 
 
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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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