Letter to Judge Kaplan — United States v. Heaven West (S.D.N.Y., Dkt. 101)

Summary

A letter dated October 22, 2023 to United States District Judge Lewis A. Kaplan in United States v. Heaven West, 21 Cr. 729 (LAK), signed /s/ by Emilee A. Sahli, Esq., who writes that Sahli and Marlon G. Kirton represent Heaven West. The letter requests an adjustment of bail conditions so that Ms. West may travel to Houston, Texas from October 27, 2023, through November 1, 2023, for a family visit. It states that the current conditions limit travel to the Southern and Eastern Districts of New York and Northern Districts of Georgia, that Ms. West is still employed and in compliance, and that Pretrial Services and the Government have no objection.

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CRSELALAOOTZAAK Dacument 100 Filled 10/22/23 Page 1 of 1

195 BROADWAY, 4™ FLOOR
BROOKLYN, NY 11211
LAW & TECH PH: 347-378-8132

Www.SAHLILAW.COM

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October 22, 2023 USDC SDNY
Won Lewis A. Kaplan DOCUMENT
United States District Judge ELECTRONICALLY FILED
Daniel Patrick Moynihan DOC #:
United States Courthouse DATE FILED: (0 “a4 -23
500 Pearl Street

New York, NY 10007

RE: United States v. Heaven West, 21 Cr. 729 (LAK)

Dear Judge Kaplan:

1, along with Marlon G. Kirton, represent Heaven West in the above-referenced matter. | request an
adjustment of Ms. West’s bail conditions to allow her to travel to Houston, Texas from October 27,
2023, through November 1, 2023, for a family visit.

The current bail conditions for Ms. West limit travel to the Southern and Eastern Districts of New York
and Northern Districts of Georgia, and districts between for travel to court, meetings with counsel, and
medical appointments. Ms. West is still employed and still in compliance with her conditions of release.

The Defense requests that the Court modify the conditions of her bail to allow Ms. West to travel to
Houston, Texas for a family visit. Pretrial Services has Ms. West’s complete itinerary. Pretrial Services
and the Government have no objection to this request.

Please contact me if you have any questions or concerns.
Very truly yours,

/s/ Emilee Sahli
Emilee A. Sahli, Esq.

cc: Michael Neff, Assistant United States Attorney (via email) (i Lf.
Marlon G. Kirton, Esq. (via email) Cau .

SO ORDE

LEWIS A. KAPLAN,

Date 10- 23-2023

SAHLI LAW, PLLC, 195 BROADWAY, 4 FLOOR, BROOKLYN, NY 11211
PH: 347-378-8132 | Www.SAHLILAW.COM


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