Court filing — E.D.N.Y. No. 2:21-cr-00363 (Dkt. 9, E.D.N.Y.)
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Case 2:21-cr-00363-GRB Document9 Filed 11/29/21 Page 1 of 1 PagelD #: 27 Ronald G. Russo SCHLAM STONE & DOLAN LLP Of Counsel 212 344-5400 Ext. 323 26 Broadway, New York, NY 10004 rrusso@schlamstone.com Main: 212 344-5400 Fax: 212 344-7677 schlamstone.com Via Pacer ; November 26, 2021 Honorable Judge Gary R. Brown US District Court Judge 100 Federal Plaza Central Islip, NY 11722-9014 Re: U.S v. Konstantinos Zarkadas, Case No. 21-CR-363 (GRB) Dear Judge Brown: The Court’s file will reflect that my client, Konstantinos Zarkadas, pled guilty before your Honor on November 12, pursuant to a plea agreement entered with the U.S. Attorney. His plea was entered remotely as he had tested positive for the COVID-19 virus that week. He was released upon a personal recognizance bond which he and his wife promptly signed. More recently, my client’s physician cleared him to come to court which he did on Tuesday, November 23, at which time he surrendered to the United States Marshal for processing, complied with several conditions of his plea agreement, and met with Officer Donna Mackey of Pretrial Services at which time he surrendered his passport. At the time of his release, my client’s travel limits were set at the Eastern and Southern District of New York. At my client’s request, | have spoken with both AUSA Anthony Bagnuolo and Officer Mackey and asked if they would consent to an extension of my client’s travel restrictions to the continental United States. Neither has any objection. Accordingly, | request that the Court enter an Order so modifying his travel limits. ectfully submitted, Cc: Anthony Bagnuolo, Esq., Assistant U.S. Attorney Officer Donna Mackey, U. S. Pretrial Services
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