Court filing
Letter Motion for International Travel Permission — U.S. v. Martinez (S.D.N.Y. No. 1:22-cr-00251)
Filed February 13, 2026 in U.S. v. Martinez; one of 32 filings from this case.
Record facts
| Court | U.S. District Court for the Southern District of New York |
|---|---|
| Filed | 2026-02-13 |
U.S. District Court for the Southern District of New York · No. 1:22-cr-00251-LJL · Doc. 109 · 2026-02-13 · Docket on CourtListener
Full text
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 February 13, 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 permission for Mr. Martinez to travel to the Dominican Republic to visit his ailing mother, who is 93 years old, is on full-time oxygen, and has a pacemaker. The purpose of the trip is to allow Mr. Martinez to assist his mother—for whom he is power of attorney—with legal affairs pertaining to her estate. During the trip Mr. Martinez intends to reside with his mother in San Cristobal, Dominican Republic. Mr. Martinez would depart on February 23, 2026 and return to the United States on March 3, 2026. He also seeks permission to travel to the Dominican Republic for a follow up trip approximately 30-45 days after his March 3, 2026 return to the United States to complete the filings necessary to get his mother’s legal affairs in order. 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 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. Mr. Martinez’s probation officer, Larren Riley, approves of Mr. Martinez’s travel plans but, given the international nature of the travel, requested that Mr. Martinez receive permission of the Court as well. While he is away, Mr. Martinez will make arrangements to check in with his probation officer every day and will remain available to his probation officer for the duration of the trip. While he is in the Dominican Republic, Mr. Martinez would continue to be subject to all other conditions of his supervised release. He will also provide his probation officer with his specific travel itinerary if this request is granted. 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. He will continue to be compliant while he visits his mother during this sensitive time. He therefore respectfully requests that the Court grant him this travel request. Case 1:22-cr-00251-LJL Document 109 Filed 02/13/26 Page 1 of 2 MEMO ENDORSEMENT. Permission granted. The Government shall respond by February 20, 2026 whether there is any reason that the travel restriction should not be lifted. 2/17/2026 Case 1:22-cr-00251-LJL Document 110 Filed 02/17/26 Page 1 of 2 - 2 - 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 109 Filed 02/13/26 Page 2 of 2 Case 1:22-cr-00251-LJL Document 110 Filed 02/17/26 Page 2 of 2
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