Home/Source documents/permission for Mr. Martinez to travel on two brief trips. This application is made without
permission for Mr. Martinez to travel on two brief trips. This application is made without
Document type
Brief
Date
2022-04-27
Case
U nited States v. Rafael Martinez,
Full text
tkasulis@maglaw.com
(212) 880-9555
April 27, 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 the Court’s
permission for Mr. Martinez to travel on two brief trips. This application is made without
objection by Pretrial Services or the government.
Mr. Martinez has been at liberty since he was arrested on February 28, 2022 and
presented before Your Honor on March 1. Mr. Martinez’s bond currently permits him to travel
within the Southern and Eastern Districts of New York, the District of New Jersey, and the
District of Connecticut.
On May 5, Mr. Martinez seeks to travel to Chicago to help his daughter select an
apartment and settle in for her university medical fellowship. He would return on May 7. On
May 10, Mr. Martinez seeks to travel to Las Vegas with his family on a graduation trip for his
daughter. He would return on May 11. This trip was booked and paid for months ago, and in
advance of Mr. Martinez’s arrest in this case.
04/27/2022
Case 1:22-cr-00251-LJL Document 17 Filed 04/27/22 Page 1 of 2
On April 26, we advised Mr. Martinez’s Pretrial Services Officer and the assigned
Assistant United States Attorney of this proposed travel, and each indicated that they had no
objection to this application.
We thank the Court for its consideration of this matter.
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 Micah Fergenson (via email)
Case 1:22-cr-00251-LJL Document 17 Filed 04/27/22 Page 2 of 2