Motion to Modify Conditions of Release Requesting Access to Passport — USA v. Ebrahimzadeh (Dkt. 46, D. Mass.)

Record facts

U.S. District Court for the District of Massachusetts · No. 1:25-cr-10455-RGS · Doc. 46 · 2026-04-22 · Docket on CourtListener

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UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF MASSACHUSETTS 
UNITED STATES OF AMERICA, 
v. 
DAVID EBRAHIMZADEH, 
Defendant. 
 
No. 1:25-cr-10455 
 
 
DEFENDANT’S MOTION REQUESTING ACCESS TO PASSPORT  
FOR UPCOMING INTERNATIONAL 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 for an upcoming international trip to Paris, France between 
May 4 and 7, 2026:  
1. Mr. Ebrahimzadeh is seeking to travel to Paris, France with his wife to celebrate their 
upcoming anniversary.  
2. Mr. Ebrahimzadeh has known about this investigation for multiple years and traveled 
domestically and internationally during that time, always returning. 
3. Likewise, Mr. Ebrahimzadeh has traveled since being indicted in this case—including 
internationally, with this Court’s permission (ECF No. 20)—and has always returned.  
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.   
5. Mr. Ebrahimzadeh requested the Government’s and Pretrial Services’ respective 
positions on this Motion. The Government indicated that it opposes all international 
Case 1:25-cr-10455-RGS     Document 46     Filed 04/22/26     Page 1 of 3

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travel during the pendency of this case, and Pretrial Services indicated that it takes no 
position on international travel requests. 
Accordingly, Mr. Ebrahimzadeh respectfully requests the Court grant him permission to 
obtain his passport for a trip to Paris, France between May 4–7, 2026. 
Dated: April 22, 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 46     Filed 04/22/26     Page 2 of 3

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CERTIFICATE OF SERVICE 
 
I hereby certify that the foregoing document was filed electronically on April 22, 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.  
 
/s/ R. Scott Seitz       
R. Scott Seitz 
 
Case 1:25-cr-10455-RGS     Document 46     Filed 04/22/26     Page 3 of 3

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