Court filing
Government's Letter Regarding Discovery and Bail-Violation Factors — United States v. Adedayo Ilori
Summary
A letter from the United States Attorney for the Southern District of New York to the Honorable Lewis J. Liman in United States v. Adedayo Ilori, 20 Cr. 378 (LJL), dated November 15, 2021 and filed as Document 108 in No. 1:20-cr-00378-LJL. The letter reports the status of the government's production of new discovery relating to the defendant's sentencing. It states that the government anticipates asking the court to consider four violations of pretrial release as sentencing factors under 18 U.S.C. § 3553(a), involving an apartment rented under a false identity, a vehicle leased in or about September 2021, credit card purchases, and cards possessed at the time of the defendant's arrest on or about October 8, 2021. It describes productions made on October 26, 2021 and November 12, 2021 and states that review of the seized electronic devices is ongoing. The letter is two pages.
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No. 1:20-cr-00378-LJL · Doc. 108 · Docket on CourtListener
Full text
Case 1:20-cr-00378-LJL Document 108 Filed 11/15/21 Page 1 of 2
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew’s Plaza
New York, New York 10007
November 15, 2021
BY ECF
The Honorable Lewis J. Liman
United States District Judge
Southern District of New York
500 Pearl Street
New York, New York 10007
Re: United States v. Adedayo Ilori, 20 Cr. 378 (LJL)
Dear Judge Liman:
The Government writes to inform the Court regarding the status of the production of new
discovery relating to the defendant Adedayo Ilori’s sentencing. At sentencing, the Government
anticipates requesting that the Court consider the following four relatively discrete violations of
pretrial release as relevant sentencing factors pursuant to 18 U.S.C. § 3553(a): (1) in or about
summer 2021, the defendant Adedayo Ilori rented an apartment at 123 Melrose Street in Brooklyn
using a false identity, (2) in or about September 2021, the defendant leased a Mercedes using a
stolen identity, (3) in or about summer and fall 2021, the defendant made multiple purchases using
a credit card in the name of a stolen identity, and (4) at the time of his arrest, on or about October
8, 2021, the defendant possessed various bank cards and identification cards in the names of other
individuals. 1 The Government’s recent production of discovery relevant to sentencing is focused
on these four areas.
On October 26, 2021, the Government produced the search warrant for the defendant’s
person that led to the defendant’s arrest on October 8, 2021, as well as a report summarizing the
evidence recovered during the search of the defendant’s person and the leased Mercedes. On
November 12, 2021, the Government produced the following: (1) records relating to the 123
Melrose Street Apartment; (2) records relating to the lease of the Mercedes; (3) records and
surveillance video regarding the defendant’s use of a credit card in the name of a stolen identity;
and (4) evidence recovered from a cellphone at the time of the search relating to the 123 Melrose
1
In addition, the Government continues to investigate the defendant’s role in a conspiracy to
fraudulently obtain COVID-19 relief loans and expects to charge the defendant in connection
with that conduct. The Government does not intend to ask the Court to consider the COVID-19
loan fraud scheme in imposing sentence in this case as the COVID-19 loan fraud scheme will be
the basis for separate charges.
Case 1:20-cr-00378-LJL Document 108 Filed 11/15/21 Page 2 of 2
Street Apartment. By the end of this week, the Government anticipates producing additional,
limited evidence from the cellphone regarding the lease of the Mercedes. This constitutes the
materials currently in the Government’s possession that is relevant to proving this fraud and
identity theft conduct.
The Government’s review of the electronic devices seized during the search is ongoing.
As identified in the defendant’s letter filed today, the Government has requested a 2TB drive from
defense counsel in order to provide the defendant with a complete copy of his own devices. This
production is being made to ensure that the defendant has access to any materials helpful to his
case at sentencing. Beyond the portions of data stored on the devices that has or will be produced
separately and distinctly identified as relevant to proving the pretrial release violations identified
above, the Government does not currently intend to rely on additional evidence from the devices.
To the extent the Government obtains any additional evidence relevant to proving the defendant’s
commission of the four additional bail violations enumerated above, it will provide it to the defense
promptly and specifically identify its import.
Respectfully submitted,
DAMIAN WILLIAMS
United States Attorney
By: /s/
Cecilia Vogel
Tara LaMorte
Daniel G. Nessim
Assistant United States Attorneys
(212) 637-1084 / -1041 / -2486
Cc: Brooke Cucinella (via ECF)
2
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