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Letter to Magistrate Judge Katharine H. Parker, April 27, 2022 — United States v. Rafael Martinez, Case 1:22-cr-00251, Doc. 16 (Filed 04/27/22)

Document type
Motion
Date
2022-04-27
Case
United States v. Rafael Martinez,

Summary

A letter motion dated April 27, 2022 and filed as Document 16 in United States v. Rafael Martinez, Case 1:22-cr-00251-LJL, addressed to United States Magistrate Judge Katharine H. Parker of the Southern District of New York under the reference 22 Mag. 1988 (S.D.N.Y.). Defense counsel ask the Court's permission for Mr. Martinez to take two brief trips, one to Chicago and one to Las Vegas. The letter states that his bond currently permits travel within the Southern and Eastern Districts of New York, the District of New Jersey and the District of Connecticut, that he has been at liberty since his arrest on February 28, 2022, and that Pretrial Services and the Assistant United States Attorney each indicated they had no objection. The two-page letter is signed by Telemachus P. Kasulis of Morvillo Abramowitz Grand Iason & Anello, P.C., with co-counsel from Willkie Farr & Gallagher LLP.

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Cite this document

“Letter to Magistrate Judge Katharine H. Parker, April 27, 2022 — United States v. Rafael Martinez, Case 1:22-cr-00251, Doc. 16 (Filed 04/27/22).” Original at www.justice.gov, dated 2022-04-27. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2022-04-27-united-states-v-rafael-martinez/, SHA-256 df3d6192715c934130b367b1cce0c957f51ffe00dbd1d99ba83dff8c8d53de3c.

Full text

        Case 1:22-cr-00251-LJL        Document 16         Filed 04/27/22    Page 1 of 2




                                        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.
        Case 1:22-cr-00251-LJL         Document 16       Filed 04/27/22     Page 2 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)


File and source

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CASE_SDNY_1-22-cr-00251_US-v-Martinez_doc16_LETTER-MOTION-TRAVEL_2022-04-27.pdf
Size
176,641 bytes
SHA-256
df3d6192715c934130b367b1cce0c957f51ffe00dbd1d99ba83dff8c8d53de3c
Our copy
CASE_SDNY_1-22-cr-00251_US-v-Martinez_doc16_LETTER-MOTION-TRAVEL_2022-04-27.pdf
Original
www.justice.gov
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