Court filing
Letter Motion to Modify Travel Restriction (Supervised Release) — U.S. v. Martinez (S.D.N.Y. No. 1:22-cr-00251)
Filed March 4, 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 | 2026-03-04 |
U.S. District Court for the Southern District of New York · No. 1:22-cr-00251-LJL · Doc. 111 · 2026-03-04 · 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 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 - 2 - 135212402.v1 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
File and source
- File
- gov.uscourts.nysd.579149.111.0.pdf
- Size
- 184,193 bytes
- SHA-256
- f5d202ec78cf2a3b2e206418da07551421e556d4b3934a329b65cc762f506090
- Original
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