Motion to Permit Domestic Travel — United States v. Aticha Jittaphol (D. Mass.)

Record facts

U.S. District Court, District of Massachusetts · No. 1:21-cr-10270-MLW · Doc. 25 · 2022-01-19 · Docket on CourtListener

Full text

UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF MASSACHUSETTS 
 
 
 
 
 
 
United States of America   
 
 
 
No. 21-CR-10270-MLW                             
        v. 
Aticha Jittaphol 
 
 
     
DEFENDANT’S MOTION TO PERMIT DOMESTIC TRAVEL 
 
 
 
Aticha Jittaphol hereby moves the Court to eliminate any restriction on 
travel within the United States from the conditions of release. 
 
An Information was filed on September 13th, together with a “C” plea 
agreement, providing for Ms. Jittaphol to plead guilty to two counts of making 
false statements in violation of 18 U.S.C. § 1001, and for a sentence of 36 months 
of probation with no incarceration. 
 
Counsel was appointed in July 2021. For two months after that, Ms. 
Jittaphol was aware that federal criminal charges were imminent. She did not 
know what the resolution was likely to be until a plea agreement was entered in 
September. During those months, this Court imposed no restriction on her ability 
to travel; an Information was not filed until September. As early as February 2021, 
she knew that she was a target of a criminal investigation, after law enforcement 
agents came to her massage parlor. She made no attempt to flee. 
 
Now she awaits sentencing with a “C” plea agreement providing for no 
incarceration. There is no risk of flight – none. 
 
Ms. Jittaphol is an accomplished volleyball player. She is on two Boston Ski 
& Sports Club teams that participate in different leagues. League games are twice a 
Case 1:21-cr-10270-MLW     Document 25     Filed 01/19/22     Page 1 of 3

 
2 
week; she attends practices on other days. On occasion, the teams travel out-of-
state to participate in tournaments. While this case has been pending, she has 
missed tournaments in Rhode Island and New Orleans. There is no reason to bar 
Ms. Jittaphol from traveling to participate in volleyball tournaments. 
 
Ms. Jittaphol’s participation in volleyball is another reason that in-patient 
treatment would prove extremely depressing. It is a big part of her life. She enjoys 
it and enjoys the comradeship of her teammates. There is no reason to deprive her 
of this based on pure speculation that her chances of avoiding relapse are better if 
she is confined to an in-patient residential treatment program.  
 
She also has been offered temporary job opportunities in other states. A 
friend has offered her occasional work in providing massage therapy instruction to 
trainees in New York. 
 
More generally, there is no reason to bar domestic travel. The purpose of 
the restriction is to reduce the risk of flight. In this case, there is no risk. 
 
 
For these reasons, Ms. Jittaphol’s probation conditions should not restrict 
domestic travel. 
ATTICHA JITTAPHOL 
By her Attorney, 
 
/s/ Keith Halpern 
Keith Halpern, BBO # 545282  
572 Washington Street, Suite 19 
Wellesley, MA 02482 
(617) 722-9952 
 
 
Case 1:21-cr-10270-MLW     Document 25     Filed 01/19/22     Page 2 of 3

 
3 
  CERTIFICATE OF SERVICE 
I hereby certify that this document, filed through the ECF system, will be sent 
electronically to the registered participants as identified on the Notice of Electronic Filing 
(NEF) and paper copies will be sent to those indicated as non-registered participants on 
January 19, 2022. 
/s/ Keith Halpern 
Case 1:21-cr-10270-MLW     Document 25     Filed 01/19/22     Page 3 of 3

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