MEMO ENDORSEMENT 111 LETTER MOTION as to Rafael Martinez (1)....ENDORSEMENT...The… — USA v. Martinez (Dkt. 112)

Record facts

U.S. District Court for the Southern District of New York · No. 1:22-cr-00251-LJL · Doc. 111 · 2026-03-05 · Docket on CourtListener

Summary

A memo endorsement entered March 5, 2026 as Document 112 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, endorsing a March 4, 2026 letter motion (Document 111) from defense counsel at Willkie Farr & Gallagher LLP. The letter asks Judge Lewis J. Liman to modify the travel restriction imposed as a condition of Mr. Martinez's 3-year term of supervised release, which began December 30, 2025. It states that the Government did not file a response by the February 20, 2026 deadline the Court set, and that the probation officer supports the change if advance notice of travel is given. The endorsement permits domestic and international travel at Probation's discretion, with advance notification of dates, method and lodging, without prejudice to further applications.

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787 Seventh Avenue 
New York, NY 10019-6099 
Tel:  212 728 8000 
Fax: 212 728 8111 
NEW YORK    WASHINGTON    HOUSTON    PALO ALTO    SAN FRANCISCO    CHICAGO    PARIS    LONDON    FRANKFURT    BRUSSELS    MILAN    ROME 
March 4, 2026 
VIA ECF 
The Honorable Lewis J. Liman 
United States District Court 
Southern District of New York 
500 Pearl Street 
New York, NY 10007 
Re: United States v. Rafael Martinez, 22-CR-251 (LJL) 
Dear Judge Liman: 
 
Counsel for Rafael Martinez respectfully submits this letter to request that the Court modify 
the travel restriction that is a condition of his supervised release.  Mr. Martinez is currently serving 
a 3-year term of supervised release that began on December 30, 2025.  One of the conditions of 
Mr. Martinez’s supervised release is that he “must not knowingly leave the federal judicial district 
where [he is] authorized to reside without first getting permission from the court or the probation 
officer.”  [ECF No. 82 at 4.]   
On February 13, 2026, Mr. Martinez asked the Court for permission to travel to the 
Dominican Republic to assist his ailing, 93-year-old mother with legal affairs pertaining to her 
estate. [ECF No. 109.]  The Court granted Mr. Martinez’s request and also instructed the 
Government to “respond by February 20, 2026 whether there is any reason that the travel 
restriction should not be lifted.”  [ECF No. 110.]  The Government did not file a response.  
Meanwhile, Mr. Martinez visited his mother without incident while keeping Probation apprised of 
his itinerary.  
Mr. Martinez now asks that the Court modify the travel restriction as a condition to his 
supervised release.  The deteriorating state of his mother’s health will require him to travel to the 
Dominican Republic frequently in the coming months.  Additionally, Mr. Martinez is pursuing 
business opportunities that also require international travel.   
Mr. Martinez has a full record of compliance during pretrial supervision in this case, his 
term of incarceration at FCI Lewisburg, his stay at a residential reentry management center, and 
home confinement.  His Probation Officer, Larren Reilly, also approves of modifying the travel 
restriction on the condition that Mr. Martinez provide advance notice to Probation of his travel 
arrangements.  Given that the Government did not object when the Court asked if there was any 
reason to retain the travel restriction, Mr. Martinez’s history of compliance, and his Probation 
Officer’s support, Mr. Martinez respectfully requests that the Court modify the travel restriction 
Case 1:22-cr-00251-LJL     Document 111     Filed 03/04/26     Page 1 of 2
MEMO ENDORSEMENT.
The conditions of Mr. Martinez’s bail are modified to permit 
him to travel domestically and internationally at Probation’s 
discretion provided he give advanced notification to Probation 
of the travel which will include the dates, method, and lodging 
information prior to being approved.  This order is without 
prejudice to further applications by Mr. Martinez for relief from 
the travel restrictions. 
3/5/2026
Case 1:22-cr-00251-LJL     Document 112     Filed 03/05/26     Page 1 of 2

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as a condition of his supervised release and permit him to travel both domestically and 
internationally, so long as he provides advance notice to Probation of his travel plans.   
 
Sincerely, 
WILLKIE FARR & GALLAGHER LLP 
 
 
 
/s/ Michael S. Schachter  
 
 
 
 
 
Michael S. Schachter  
 
 
 
 
 
 
 
 
 
 
 
 
cc: AUSA Micah Fergenson (via ECF) 
Case 1:22-cr-00251-LJL     Document 111     Filed 03/04/26     Page 2 of 2
Case 1:22-cr-00251-LJL     Document 112     Filed 03/05/26     Page 2 of 2

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