Consent Letter Motion — United States v. Vanessa Gomez, et al., 21 Cr. 245 (Document 73)

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A consent letter motion dated November 1, 2022 from attorney Thomas H. Nooter to Judge Edgardo Ramos in United States v. Vanessa Gomez, et al., 21 Cr. 245 (ER), in the U.S. District Court for the Southern District of New York, filed November 8, 2022 as Document 73. It states that Gomez was sentenced on May 11, 2022 to time served and three years of supervised release, six months of it on home confinement, ending November 15, 2022. It asks permission for her to travel to the Dominican Republic over the Thanksgiving holiday, with dates to be coordinated with her probation officer. The memo endorsement, signed by Edgardo Ramos, U.S.D.J., on November 7, 2022, grants the application.

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Case 1:21-cr-00245-ER Document 73 Filed 11/08/22 Page 1 of 2

FREEMAN, NOOTER & GINSBERG

ATTORNEYS AT LAW
LOUIS M. FREEMAN 75 MAIDEN LANE
THOMAS H. NOOTER* SUITE 503
LEE A. GINSBERG NEW YORK, N.Y. 10038
(212) 608-0808
*NY AND CALIF. BARS TELECOPIER (212) 962-9696

November 1, 2022
Honorable Edgardo Ramos

United States District Judge MEMO ENDORSED. Pg. 2.

Southern District of New York

Thurgood Marshal Courthouse

40 Foley Square

New York, NY 10007 CONSENT LETTER MOTION

RE: United States v. Vanessa Gomez, et al., 21 Cr. 245 (ER)

Your Honor:

I am the attorney who represented Ms. Gomez during the time her case was
pending before Your Honor earlier this year.

Ms. Gomez was sentenced on May 11, 2022, to “time served,” to be
followed by three years supervised release, of which six months is to be served on
home confinement.

On November 15, 2022 Ms. Gomez is expected to be finished with the
home confinement portion of the sentence, but will remain on supervised release.

I am writing on her behalf now to respectfully request permission for her to
travel outside of the United States for a brief trip to the Dominican Republic
during the Thanksgiving holiday. The exact dates will depend on what flight
arrangements she can make, but she will coordinate with her Probation Officer on
the dates. She expects to stay with her mother at the “Residencia Odette, C.
Vientos del Sur in Santo Domingo for about four days.

The reason for the request is for her to see her 90-year-old grandmother,
who is apparently somewhat close to dying, as well as visit her mother.

Ms. Gomez is supervised by USPO Pierre Reyes, phone number is (646)
Case 1:21-cr-00245-ER Document 73 Filed 11/08/22 Page 2 of 2

300-5334 who has no objection, but needs the Court’s permission to allow her to
travel outside of the country.

I have also consulted with the Assistant United States Attorney who handled

her case for the government, Ms. Danielle M. Kudla, Esq., and she has no
objection.

I thank the Court in advance for Your Honor’s consideration of this
application.

Sincerely,

/s/ Thomas H. Nooter
Attorney for Defendant Vanessa Gomez

cc: AUSA Danielle M. Kudla, by ECF
USPO Pierre Reyes, by email

The application to travel outside of the United States as described above is granted.
The Clerk of the Court is respectfully directed to terminate the motions, docs. 71
and 72.

SO ORDERED.

Edgardo Ramos, U.S.D.J
Dated: 11/7/2022

New York, New York


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