Motion - United States v. Rafael Martinez, (2022-07-12)
Document type
Motion
Date
2022-07-12
Case
United States v. Rafael Martinez,
Full text
tkasulis@maglaw.com
(212) 880-9555
July 12, 2022
Hon. Lewis J. Liman
United States District Judge
Southern District of New York
500 Pearl Street
New York, New York 10007
Re:
United States v. Rafael Martinez,
22 Cr. 251 (LJL)
Dear Judge Liman,
We represent Rafael Martinez in the above-captioned case and seek the Court’s
permission for Mr. Martinez to travel on a brief trip outside the bail limits imposed by this Court.
Mr. Martinez has been at liberty since he was arrested on February 28, 2022 and
presented before Hon. Katherine H. Parker on March 1. Mr. Martinez’s bond currently permits
him to travel within the Southern and Eastern District of New York, the District of New Jersey,
the District of Connecticut, and the District of Massachusetts.
Mr. Martinez seeks to travel to California for several days to participate in the Stanford
University executive program. On July 15, 2022, he is scheduled to depart from Newark, New
Jersey at 6:30am and to arrive in San Francisco, California at 9:25am. He plans to stay at the
Fairmont hotel in San Francisco. He is scheduled to depart from San Francisco on July 18 at
9:00pm and to arrive in Newark on July 19 at 5:15am. Mr. Martinez’s participation in the
program was approved in November 2021 and this trip was booked in advance of Mr. Martinez’s
arrest in this case.
On June 30, 2022, we advised Mr. Martinez’s Pretrial Services Officer and the assigned
Assistant United States Attorney of this proposed travel. On July 11, Pretrial Services indicated
Case 1:22-cr-00251-LJL Document 25 Filed 07/12/22 Page 1 of 2
Hon. Lewis J. Liman
P. 2
that they had no objection to this application, and the government indicated that it takes no
position.
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. Schacter
Randall Jackson
Counsel for Rafael Martinez
cc:
AUSA Micah Fergenson
Case 1:22-cr-00251-LJL Document 25 Filed 07/12/22 Page 2 of 2