Court filing

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

Summary

Document 46, a three-page Defendant's Motion Requesting Access to Passport for Upcoming International Travel filed 04/22/26 in the District of Massachusetts, No. 1:25-cr-10455, United States v. David Ebrahimzadeh. Under his conditions of release he seeks to get his passport from the New York Pretrial Services Office for a trip to Paris, France with his wife between May 4 and 7, 2026 for an anniversary. He says he has traveled during the investigation and since indictment, including abroad with permission in ECF No. 20, always returning, and has no other citizenship. The government opposes all international travel during the case, and Pretrial Services takes no position. The motion carries a certificate of consultation under Local Rule 7.1(a)(2).

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Filed April 22, 2026 in USA v. Ebrahimzadeh; one of 35 filings from this case.

Record facts

Court	U.S. District Court for the District of Massachusetts
Filed	2026-04-22

Cite this document

“Motion to Modify Conditions of Release Requesting Access to Passport — USA v. Ebrahimzadeh (Dkt. 46, D. Mass.).” U.S. District Court for the District of Massachusetts, No. 1:25-cr-10455-RGS, Doc. 46, filed 2026-04-22. Archived at Pandemic Darlings, https://pandemicdarlings.com/court-filings/full-docket-david-ebrahimzadeh-mad-293123/2026-04-22-gov-uscourts-mad-293123-46-0-doc-46/, SHA-256 a73b9e744f3bc9014a8282b354e55c1fb709d8f099ba8bddd6b04f1747b51468.

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Full text

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

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

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.