Assented to Motion to Modify Conditions of Release — USA v. Ebrahimzadeh (Dkt. 44, D. Mass.)

Record facts

U.S. District Court for the District of Massachusetts · No. 1:25-cr-10455-RGS · Doc. 44 · 2026-03-30 · Docket on CourtListener

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UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF MASSACHUSETTS 
UNITED STATES OF AMERICA, 
v. 
DAVID EBRAHIMZADEH, 
Defendant. 
Case No. 1:25-cr-10455 
DEFENDANT’S MOTION REQUESTING ACCESS TO PASSPORT  
FOR UPCOMING DOMESTIC TRAVEL  
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 to travel to Miami, Florida between April 3–11, 2026.  In 
support of this motion, undersigned counsel states as follows:  
1. Mr. Ebrahimzadeh does not currently hold a REAL ID but has taken all the steps 
required to get one and is now simply waiting to receive it in the mail.  
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 has traveled both domestically and 
internationally pursuant to his conditions of release.  
4. 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. 
5. Neither the Government nor Pretrial Services objects to the return of Mr. 
Ebrahimzadeh’s passport for his planned domestic travel as described herein. 
Case 1:25-cr-10455-RGS     Document 44     Filed 03/30/26     Page 1 of 3

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Accordingly, Mr. Ebrahimzadeh respectfully requests the Court grant him permission to 
obtain his passport for his domestic travel on April 3–11, 2026. 
Dated: March 30, 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 
Case 1:25-cr-10455-RGS     Document 44     Filed 03/30/26     Page 2 of 3

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CERTIFICATE OF SERVICE
I hereby certify that the foregoing document was filed electronically on March 30, 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 
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 
Case 1:25-cr-10455-RGS     Document 44     Filed 03/30/26     Page 3 of 3

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