Defendant Feroz Jalal’s Unopposed Motion to Modify Conditions of Release — United States v. Jalal (Dkt. 145, N.D. Ill.)

Summary

An unopposed motion by defendant Feroz Jalal to modify conditions of release, filed May 8, 2025 as Document 145 in United States v. Jalal, No. 23 CR 369-1, in the U.S. District Court for the Northern District of Illinois. It asks the court to remove his electronic monitoring bracelet on May 16, 2025, before his surrender to FCI Thompson on May 19, 2025, and to allow movement that day to St. Francis Evanston hospital for an MRI. The motion states that the grand jury returned a four-count indictment on October 26, 2023 charging three counts of bank fraud under 18 U.S.C. § 1344 and one count of money laundering, and that the court sentenced Jalal on February 11, 2025 to 62 months' imprisonment. It is signed by defense attorney Vadim A. Glozman.

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Case: 1:23-cr-00369 Document #: 145 Filed: 05/08/25 Page 1 of 4 PageID #:1352




                 IN THE UNITED STATES DISTRICT COURT
                FOR THE NORTHERN DISTRICT OF ILLINOIS
                           EASTERN DIVISION


 UNITED STATES OF AMERICA,                  )
                                            )
                Plaintiff,                  )
                                            )   No.: 23 CR 369-1
 vs.                                        )
                                            )   Hon. John F. Kness
 FEROZ JALAL, et al.,                       )
                                            )
              Defendants.                   )

       DEFENDANT FEROZ JALAL’S UNOPPOSED MOTION TO MODIFY
                     CONDITIONS OF RELEASE

        Now comes the defendant, Feroz Jalal, by and through his undersigned

attorney, and respectfully moves this Honorable Court to enter an order modifying

the conditions of release to remove his electronic monitoring bracelet on May 16,

2025, pending his surrender to FCI Thompson on May 19, 2025, and allow additional

movement to St. Francis Evanston hospital on May 16, 2025, for a 1:30pm MRI. In

support, the following is offered:

        1.   On October 26, 2023, the grand jury returned a four-count indictment

charging Mr. Jalal with three counts of bank fraud in violation of 18 U.S.C. § 1344,

and one count of money laundering in violation of 18 U.S.C. §1957.

        2.   As part of his conditions of pretrial release, Mr. Jalal is subject to home

incarceration with electronic monitoring.

   Case: 1:23-cr-00369 Document #: 145 Filed: 05/08/25 Page 2 of 4 PageID #:1353




      3.     On February 11, 2025, this Court sentenced Mr. Jalal to a term of 62

months’ imprisonment. He has a surrender date of May 19, 2025 at 2:00pm, at which

time he will be surrendering to FCI Thompson in Thompson, Illinois.

      4.     Mr. Jalal has an MRI appointment with Dr. Jame M. Voci at the St.

Francis Evanston Hospital located at 800 Austin St., Evanston, Illinois 60202 at

1:30pm on May 16, 2025, 3 days prior to his surrender to the Bureau of Prisons. The

undersigned has provided proof of the appointment to both the government and

Pretrial Services. As this Court knows based on Mr. Jalal’s prior request to get an

MRI, the electronic monitoring bracelet must be removed prior to the procedure.

      5.     Upon contacting the government and Pretrial Services regarding this

request, Pretrial Services Officer Daniel Dominguez suggested that since Mr. Jalal is

surrendering 3 days after the MRI, that he not be put back on the electronic

monitoring bracelet once it is removed the morning of May 16, 2025.

      6.     This Court has previously removed Mr. Jalal’s electronic monitoring

bracelet for purposes of an MRI with no incident. Dkt. 76.

      7.     Neither the government nor Pretrial Services have any objection to

removing his electronic monitoring bracelet the morning of May 16, 2025 pending his

surrender, and allowing him to go to St. Francis Evanston Hospital for an MRI so

long as Mr. Jalal remain in touch telephonically with Pretrial Services after his

appointment to confirm he is back home and when he leave for FCI Thompson on

May 19, 2025. Mr. Jalal will so abide.




                                         2

  Case: 1:23-cr-00369 Document #: 145 Filed: 05/08/25 Page 3 of 4 PageID #:1354




      Wherefore, for the reasons stated above, defendant Feroz Jalal respectfully

moves this Honorable Court to enter an order modifying the conditions of his release

to remove his electronic monitoring bracelet on May 16, 2025, pending his surrender

to FCI Thompson on May 19, 2025, and allow additional movement to St. Francis

Evanston hospital on May 16, 2025, for a 1:30pm MRI. Respectfully submitted,


                                             /s Vadim A. Glozman
                                             Attorney for Feroz Jalal

                                             GLOZMAN LAW
                                             53 W. Jackson Blvd., Suite 1150
                                             Chicago, IL 60604
                                             (312) 726-9015




                                         3

   Case: 1:23-cr-00369 Document #: 145 Filed: 05/08/25 Page 4 of 4 PageID #:1355




                           CERTIFICATE OF SERVICE

      I, Vadim A. Glozman, an attorney for Defendant Feroz Jalal, hereby certify

that on this, the 8th day of May 2025, I filed the above-described document on the

CM-ECF system of the United States District Court for the Northern District of

Illinois, which constitutes service of the same.

                                               Respectfully submitted,


                                               /s/ Vadim A. Glozman____




                                           4

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