United States v. Rafael Martinez

Summary

A letter dated March 8, 2022 from defense counsel to United States Magistrate Judge Katharine H. Parker in United States v. Rafael Martinez, 22 Mag. 1988 (S.D.N.Y.), filed as Document 10 in Case 1:22-cr-00251-LJL. Counsel asks for a one-week extension of the date by which the defendant must satisfy his outstanding bail conditions and states that the government consents. The letter states that he was arrested on February 28, 2022, presented on a Complaint, and that the court approved a bail package including a $10 million personal recognizance bond cosigned by three financially responsible people and secured by four designated properties, with travel restrictions and Pretrial Services supervision. It is signed by Telemachus P. Kasulis of Morvillo Abramowitz Grand Iason & Anello, P.C.; the signature block also lists counsel from Willkie Farr & Gallagher LLP.

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Full text

        Case 1:22-cr-00251-LJL        Document 10         Filed 03/08/22    Page 1 of 2




                                        tkasulis@maglaw.com
                                            (212) 880-9555


                                         March 8, 2022

Hon. Katharine H. Parker
United States Magistrate Judge
Southern District of New York
500 Pearl Street
New York, New York 10007

       Re:    United States v. Rafael Martinez,
              22 Mag. 1988 (S.D.N.Y.)

Dear Judge Parker:

        We represent Rafael Martinez in the above-captioned case and seek a one-week extension
of the date by which Mr. Martinez must satisfy his outstanding bail conditions. The government
consents to this request.

        Mr. Martinez was arrested on February 28, 2022 and was presented on a Complaint
remotely before Your Honor on March 1. The Court approved the following bail package: (1) a
$10 million personal recognizance bond; (2) cosigned by three financially responsible people; (3)
secured by four designated properties; (4) with travel restricted to the Southern and Eastern
Districts of New York and the District of New Jersey; (5) the surrender of any firearms; (6)
supervision as directed by Pretrial Services; and (7) the surrender of any travel documents. Your
Honor allowed Mr. Martinez to be released upon his own signature with the balance of the
conditions to be met by March 8.

      Although Mr. Martinez is working diligently to meet the bail conditions, we cannot
complete that process by today. Accordingly, we request an extension of one week to satisfy the
        Case 1:22-cr-00251-LJL        Document 10       Filed 03/08/22     Page 2 of 2




conditions of release. We have conferred with the assigned Assistant United States Attorney,
who consents to this application.


                                            Respectfully submitted,

                                            MORVILLO ABRAMOWITZ GRAND IASON &
                                            ANELLO, P.C.

                                            /s/ Telemachus P. Kasulis
                                            Telemachus P. Kasulis
                                            Elkan Abramowitz

                                            WILLKIE FARR & GALLAGHER LLP

                                            Michael S. Schachter
                                            Randall Jackson

                                            Counsel for Rafael Martinez

cc:    AUSA Sagar Ravi


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