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Consent Letter Motion — No. 1:21-cr-00245 (Dkt. 77, 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 77 and dated March 28, 2023. Thomas H. Nooter of Freeman, Nooter and Ginsberg writes to United States District Judge Edgardo Ramos that Gomez was sentenced on May 11, 2022 to time served followed by three years of supervised release, six months of it on home confinement, which she has served, and that supervision should end on or about May 11, 2023. He asks permission for her to travel to the Dominican Republic from April 6, 2023 through April 17, 2023, with flights already booked on JetBlue, to stay with her mother and see her 90-year-old grandmother, noting it is the second such request. The second page carries the endorsement granting the application, marked SO ORDERED.

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Cite this document

“Consent Letter Motion — No. 1:21-cr-00245 (Dkt. 77, S.D.N.Y.).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/consent-letter-motion-no-1-21-cr-00245-dkt-77-s-d-n-y-3dcf31e214/, SHA-256 cb896e2a6ed1a9c04bb54643c0f73e7882ffca7f8300c6eaecb56e105ec6b261.

Full text

               Case 1:21-cr-00245-ER Document 77 Filed 03/30/23 Page 1 of 2




                             FREEMAN, NOOTER & GINSBERG
                                      ATTORNEYS AT LAW

LOUIS M. FREEMAN                                                       75 MAIDEN LANE
THOMAS H. NOOTER*                                                         SUITE 907
LEE A. GINSBERG                                                     NEW YORK, N.Y. 10038

                                                                         (212) 608-0808
*NY AND CALIF. BARS                                                    Cell: (917) 847-1361


                                     March 28, 2023

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.

      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. She served the home confinement and should be finished with
the supervised release on or about May 11, 2023.

       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 from
April 6, 2023 through April 17, 2023. She has already booked flights on JetBlue
for those dates. She expects to stay with her mother while she is there. The reason
for the request is for her to see her 90-year-old grandmother and her mother.

       This is the second such request I have made on behalf of Ms. Gomez: the
first was for the Thanksgiving holiday period, and was also on consent, and the
request was granted by the Court.

      Ms. Gomez is now supervised by Andrew Leung, (at Andrew_Leung@
nysp.uscourts.gov) who has no objection, but needs the Court’s permission to
          Case 1:21-cr-00245-ER Document 77 Filed 03/30/23 Page 2 of 2




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
       Andrew Leung, Contract employee with U.S. Probation Department




Ms. Gomez' application for permission for to travel outside of the United States for a brief trip to
the Dominican Republic from April 6, 2023 through April 17, 2023 is granted.
SO ORDERED.




         3/30/2023




                                                -2-

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