Letter to Magistrate Judge Katharine H. Parker, March 15, 2022 — United States v. Rafael Martinez, Case 1:22-cr-00251, Doc. 12 (Filed 03/15/22)
- Document type
- Complaint
- Date
- 2022-03-15
- Case
- United States v. Rafael Martinez,
Summary
A letter dated March 15, 2022 from defense counsel to Magistrate Judge Katharine H. Parker in United States v. Rafael Martinez, 22 Mag. 1988 (S.D.N.Y.), filed as Document 12 in Case 1:22-cr-00251-LJL. Counsel ask for an additional one-week extension for Mr. Martinez to satisfy his outstanding bail conditions and state that AUSA Micah Ferguson consents. It recounts that Mr. Martinez was arrested on February 28, 2022 and presented on a Complaint, and that the Court approved a bail package including a $10 million personal recognizance bond secured by four designated properties, with travel restricted to the Southern and Eastern Districts of New York and the District of New Jersey. It states that he was released on his own signature with the other conditions due by March 8, when another week was granted. It is signed by Telemachus P. Kasulis of Morvillo Abramowitz Grand Iason & Anello, P.C.
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Cite this document
“Letter to Magistrate Judge Katharine H. Parker, March 15, 2022 — United States v. Rafael Martinez, Case 1:22-cr-00251, Doc. 12 (Filed 03/15/22).”
Original at www.justice.gov, dated 2022-03-15. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2022-03-15-united-states-v-rafael-martinez/
, SHA-256 e4746d4cc1726cf017566c090d9e68146b03b65c2a11e7c39b62613cd96e1298.Full text
Case 1:22-cr-00251-LJL Document 12 Filed 03/15/22 Page 1 of 2
tkasulis@maglaw.com
(212) 880-9555
March 15, 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 an additional 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. On March 8, Your Honor granted Mr. Martinez an additional
week to satisfy these conditions upon the consent of the government.
Although Mr. Martinez is nearly finished with this process, a brief period of additional
time is needed. Accordingly, we request an extension of one week to satisfy the
Case 1:22-cr-00251-LJL Document 12 Filed 03/15/22 Page 2 of 2
remaining conditions of release. We have conferred with Assistant United States Attorney
Micah Ferguson, 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
AUSA Micah Ferguson
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- CASE_SDNY_1-22-cr-00251_US-v-Martinez_doc12_LETTER-MOTION-EXT_2022-03-15.pdf
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- 180,279 bytes
- SHA-256
- e4746d4cc1726cf017566c090d9e68146b03b65c2a11e7c39b62613cd96e1298
- Original
- www.justice.gov