CONSENT LETTER MOTION addressed to Judge Lewis J.… — USA v. Martinez (Dkt. 72)

Record facts

U.S. District Court for the Southern District of New York · No. 1:22-cr-00251-LJL · Doc. 72 · 2023-06-08 · Docket on CourtListener

Summary

A consent letter motion from the government to Judge Lewis J. Liman in United States v. Rafael Martinez, No. 1:22-cr-00251-LJL, in the U.S. District Court for the Southern District of New York, dated June 8, 2023 and filed as Doc. 72. The letter states that on March 23, 2023 the defendant pleaded guilty to Count One of the S2 Superseding Information and the court entered a Consent Preliminary Order of Forfeiture directing a money judgment of $44,546,712.94. It reports that the parties agreed to a proposed Consent Preliminary Order of Forfeiture as to Substitute Assets covering a bank account at Citibank, N.A. in the name of MBE Capital Partners LLC. The government asks the court to enter that order, which is described as executed by the government, defense counsel and the defendant. The letter is signed for United States Attorney Damian Williams.

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Full text

[Type text] 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
June 8, 2023 
 
 
BY ECF 
The Honorable Lewis J. Liman 
United States District Judge 
Daniel Patrick Moynihan United States Courthouse 
500 Pearl Street 
New York, New York 10007 
 
 
 
Re: 
United States v. Rafael Martinez, 22 Cr. 251 (LJL) 
 
Dear Judge Liman: 
 
 
 
On March 23, 2023, the defendant in the above-captioned action pleaded guilty to Count 
One of the S2 Superseding Information.  At that time, the Court also entered the Consent 
Preliminary Order of Forfeiture directing, among other things, that a money judgment in the 
amount of $44,546,712.94 be entered against the defendant.  The parties have now reached 
agreement as to the enclosed proposed Consent Preliminary Order of Forfeiture as to Substitute 
Assets (the “Order”), which provides for the forfeiture of the defendant’s right, title, and interest 
in a specific bank account held at Citibank, N.A. in the name of MBE Capital Partners LLC.  The 
Order, executed by the Government, defense counsel, and the defendant is attached for the Court’s 
consideration.  The Government respectfully requests that the Court enter the Order.  
 
Respectfully submitted, 
 
 
 
 
 
 
 
 
 
 
 
 
 
DAMIAN WILLIAMS 
 
 
 
 
 
 
 
 
 
 
 
 
United States Attorney 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
by: ___________________________ 
 
 
 
 
 
 
 
 
 
 
 
 
Katherine Reilly 
Micah F. Fergenson 
 
 
 
 
 
 
 
 
 
 
 
 
Katherine Reilly 
 
 
 
 
 
 
 
 
 
 
 
 
Assistant United States Attorneys 
 
 
 
 
 
 
 
 
 
 
 
 
(212) 637-6521/2190 
 
 
cc:  Defense Counsel (By ECF) 
 
The Silvio J. Mollo Building 
 
 
 
 
 
 
 
 
 
 
 
 
 
One Saint Andrew’s Plaza 
 
 
 
 
 
 
 
 
 
 
 
 
 
New York, New York 10007 
U.S. Department of Justice 
United States Attorney 
Southern District of New York 
Case 1:22-cr-00251-LJL     Document 72     Filed 06/08/23     Page 1 of 1

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