Consent Letter Motion — No. 1:21-cr-00245 (Dkt. 75, S.D.N.Y.)

Summary

A consent letter motion in the U.S. District Court for the Southern District of New York in United States v. Vanessa Gomez, et al., 21 Cr. 245 (ER), filed as Document 75 and dated November 11, 2022. Thomas H. Nooter of Freeman, Nooter and Ginsberg, who represented Gomez while her case was pending before United States District Judge Edgardo Ramos, writes that the Court had granted his earlier motion to let Gomez travel outside the U.S. for Thanksgiving while on supervised release, but that he had forgotten Pre-Trial Services holds her U.S. passport as a condition of release. He asks for an order releasing the passport, stating that USPO Pierre Reyes and Assistant United States Attorney Danielle M. Kudla have no objection. The second page carries the endorsement directing Pretrial Services to release the passport to Gomez, marked SO ORDERED.

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               Case 1:21-cr-00245-ER Document 75 Filed 11/14/22 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 11, 2022
Honorable Edgardo Ramos
United States District Judge
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.

       I recently made a motion to permit Ms. Gomez to travel outside of the
U.S. for Thanksgiving while still on supervised release, which was granted by the
Court.

      At the time I made the motion I failed to remember that Pre-Trial Services is
holding her U.S. passport as part of her conditions of release, so I am writing once
again to request that the Court issue an order releasing the passport to my client.

     Ms. Gomez is supervised by USPO Pierre Reyes, phone number is (646)
300-5334 who has no objection.

      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, and I am sorry I didn’t think of it at the time I made the first
application.
          Case 1:21-cr-00245-ER Document 75 Filed 11/14/22 Page 2 of 2




                                             Sincerely,

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

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




Pretrial Services is respectfully directed to release to Ms. Gomez her passport.
SO ORDERED.



           11/14/2022




                                               -2-


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