United States’ Opposition to Motion to Travel — United States v. Montalvo (Dkt. 64, D.P.R.)

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The United States' opposition to a motion to travel in United States v. Ramon J. Valentin Montalvo, No. 25-CR-163 (CVR), in the U.S. District Court for the District of Puerto Rico, filed May 5, 2025 as Document 64 by Assistant U.S. Attorney Daniel J. Olinghouse. It states that Valentin was indicted on March 27, 2025 for wire fraud conspiracy and bank bribery, arrested on April 3, 2025 and released on a $10,000 unsecured bond with conditions that allow overseas travel to the mainland U.S. only, for no more than 15 days. It opposes his April 25, 2025 request to travel to Europe for over two weeks, including a Mediterranean cruise to Ibiza, Naples and Cannes, noting that he did not say when the reservations were confirmed or paid.

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Case 3:25-cr-00163-CVR           Document 64       Filed 05/05/25      Page 1 of 4




                         IN THE UNITED STATES DISTRICT COURT
                           FOR THE DISTRICT OF PUERTO RICO

  UNITED STATES OF AMERICA,

                   v.
                                                           No.: 25-CR-163 (CVR)
  RAMON J. VALENTIN MONTALVO,

                   Defendant.


                UNITED STATES’ OPPOSITION TO MOTION TO TRAVEL

       TO THE HONORABLE COURT:

       COMES NOW the United States of America, by and through the undersigned Assistant

United States Attorney, to respectfully request that the Court deny Defendant Ramon J. Valentin

Montalvo’s Motion to Travel.

       On March 27, 2025, Valentin was indicted for wire fraud conspiracy and bank bribery.

See ECF No. 3. On April 3, 2025, he was arrested. Without objection from the United States,

Valentin was released under the condition that he put forward an unsecured bond of $10,000 and

undergo mental health and drug treatment as the U.S. Probation Office directs. See ECF No. 50.

The conditions authorize “overseas travel to mainland U.S. only, not exceeding 15 days.” See id.

       On April 25, 2025, Valentin moved for permission to travel to Europe for over two weeks

to enjoy, among other things, a Mediterranean cruise visiting such ports as Ibiza, Spain; Naples,

Italy; and Cannes, France. See ECF No. 59. He mistakenly notes in his Motion that the “travel

does not exceed the fifteen (15) day limit permitted under the conditions of release.” See id.

       Valentin informed that this luxury cruise was “previously scheduled.” See id. at 2. But

he did not provide information about when the reservations were confirmed or paid.1 And the



       1
           The documents provide the issued date, which could be different from the confirmed

        Case 3:25-cr-00163-CVR           Document 64         Filed 05/05/25      Page 2 of 4




supporting documentation submitted does not appear to be the original documentation. Instead,

it appears that information was copied into a Microsoft Word document from some other source.

See id. It is unclear from the Motion why Valentin chose to provide the information in this

manner instead of providing the original reservations.

        The Bail Reform Act, 18 U.S.C. § 3141, et seq., governs release pending trial. Section

3141 lists four factors to be considered in the detention analysis: (1) the nature and

circumstances of the crimes charged; (2) the history and characteristics of the defendant; (3) the

seriousness of the danger posed by the defendant’s release; and (4) the evidence of the

defendant’s guilt. See 18 U.S.C. § 3142(g). Courts should consider those factors when weighing

a request like Valentin’s. See United States v. Pina-Nieves, 535 F. Supp. 3d 86, 87 (D.P.R.

2021) (Besosa, J.) (denying defendant’s motion to travel to Dominican Republic for the birth of

his child).

        Valentin’s current conditions of release are adequate under the circumstances and the

Court should deny his request to travel. First, Valentin was involved in a multi-million-dollar

scheme to defraud. He leveraged his status as a certified public accountant to forge tax

documents for submission to the U.S. Small Business Administration and a bank in Puerto Rico.

        Every count to which Valentin is exposed to carries a potential 30-year sentence of

imprisonment. He is also exposed to significant monetary penalties in the form of fines,

restitution, and forfeiture. That is all in addition to the likely collateral consequences of a

conviction in this matter, including losing his ability to continue doing business as a CPA.




date.
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       Case 3:25-cr-00163-CVR           Document 64        Filed 05/05/25       Page 3 of 4




       Second, the weight of the evidence is strong. The United States expects to present

testimony from multiple witnesses, documents and records from various sources, and electronic

communications to establish Valentin’s role in the scheme. Some of those communications

come from Valentin himself.

       Third, Valentin has a criminal record. In 2003 he was convicted of violations of the

Puerto Rico controlled substances laws. Though it is not recent, it shows that Valentin is no

stranger to criminal behavior.

       Valentin, a mere month after being arrested for fraud and bribery, now asks the Court to

trust him to take a vacation to Europe. Given the nature of the charges, the weight of the

evidence, and Valentin’s history and characteristics, the United States objects. The potential

penalties and collateral consequences make him a flight risk while the two weeks of luxury travel

provide ample opportunity to dissipate assets that could be used to satisfy any monetary penalties

imposed. Accordingly, the United States asks the Court to deny the Motion. Alternatively, if the

Court is inclined to grant Valentin’s request, the United States would respectfully request that it

also impose a $50,000 secured bond.

                                                      Respectfully submitted,

                                                      W. STEPHEN MULDROW
                                                      United States Attorney

                                                      s/Daniel J. Olinghouse
                                                      Assistant United States Attorney
                                                      USDC-PR No. G03009
                                                      Torre Chardón, Suite 1201
                                                      350 Carlos Chardón Street
                                                      San Juan, Puerto Rico 00918
                                                      (787) 766-5656
                                                      Daniel.Olinghouse2@usdoj.gov




                                                 3

        Case 3:25-cr-00163-CVR           Document 64       Filed 05/05/25      Page 4 of 4




                                    aaCERTIFICATE OF SERVICE

        I hereby certify that I caused the foregoing to be presented to the Clerk of the Court for

filing and uploading to the CM/ECF system, which will generate an electronic notice of this

filing to be sent to the parties.

                                                      s/Daniel J. Olinghouse
                                                      Daniel J. Olinghouse
                                                      Assistant United States Attorney




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