Joint Stipulation to Modify Conditions (Travel) — United States v. Kofi Sarfo and Rose Sarfo (Dkt. 189)
Summary
A Joint Stipulation to Modify Conditions Upon Defendants' Travel, filed February 6, 2026 as Document 189 in United States v. Kofi Sarfo and Rose Sarfo, Case No. 2:23-cr-0132, in the U.S. District Court for the District of Nevada. The parties ask the Court to modify conditions that limit the defendants to travel within Nevada so they can travel to Ghana for a funeral, leaving Las Vegas on February 11, 2026 and returning no later than March 31, 2026. The stipulation states that the government does not oppose the request and asks that passports be returned on or before February 10, 2026. An order block dated February 6, 2026 states that the Stipulation is approved.
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“Joint Stipulation to Modify Conditions (Travel) — United States v. Kofi Sarfo and Rose Sarfo (Dkt. 189).”
Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-no-2-23-cr-00132-dkt-189-55596d0ad7/
, SHA-256 fa8450dd2bfab5552e5f907f7fbcd7b7e6ad41da3e3b276a485c1849f616fb31.Full text
Case 2:23-cr-00132-APG-EJY Document 189 Filed 02/06/26 Page 1 of 3
PAUL S. PADDA, ESQ. (NV Bar #10417)
1 Email: psp@paulpaddalaw.com
2 PAUL PADDA LAW, PLLC
4560 South Decatur Boulevard, Suite 300
3 Las Vegas, Nevada 89103
Tele: (702) 366-1888
4 Attorney for Rose Sarfo
5
UNITED STATES DISTRICT COURT
6
7 DISTRICT OF NEVADA
8
UNITED STATES OF AMERICA,
9 Case No. 2:23-cr-0132-APG-EJY
Plaintiff,
10 JOINT STIPULATION TO MODIFY
11 vs. CONDITIONS UPON DEFENDANTS’
4560 South Decatur Blvd., Suite 300
PAUL PADDA LAW, PLLC
TRAVEL
12 KOFI SARFO,
ROSE SARFO
13
Las Vegas, Nevada 89103
14 Defendants.
15
Pursuant to the Court’s Local Rule of Criminal Practice 45-1, the parties (the United
Tele: (702) 366-1888 • Fax (702) 366-1940
16
17 States, Dr. Kofi Sarfo and his wife Rose Sarfo) hereby stipulate, subject to the Court’s approval,
18 to modify the current conditions limiting Defendants’ travel. See ECF Nos. 16, p. 4 and 18, p.
19
4. Pursuant to those conditions, Dr. and Mrs. Sarfo are limited to travel within Nevada. Id.
20
Additionally, per the Court’s prior directive, they tendered their United States passports (both
21
22 are citizens) to pretrial services. Id. This Stipulation is being filed to permit the Sarfos to travel
23 to Ghana for the purpose of attending the funeral of Rose Sarfo’s brother who had a heart attack
24 and died this week. Should the Court approve this Stipulation, the Sarfos would plan to depart
25
Las Vegas for Ghana on February 11, 2026 and return to the United States no later than March
26
31, 2026. Counsel for the respective parties have discussed this and believe good cause
27
28 supports this request. Specifically, the government does not oppose this request.
1
Case 2:23-cr-00132-APG-EJY Document 189 Filed 02/06/26 Page 2 of 3
In considering this Stipulation, the Court can take notice that the Sarfos have complied
1
2 with all of the conditions of release imposed upon them and that no motion or petition has been
3 filed by pretrial services during the pendency of this criminal case alleging noncompliance on
4
the part of the Sarfos. Dr. Sarfo is a physician licensed to practice medicine in Nevada with a
5
busy and active clinic. Both he and his wife Rose own a home in Las Vegas (“Summerlin”) and
6
7 have three children in the United Sates (one is in law school in Washington, D.C., another is in
8 medical school in California and a third is an undergraduate college student, also in California).
9 In sum, the Sarfos are citizens of the United States with substantial ties to Las Vegas, which has
10
been their home for over 20-years. The government does not oppose permitting the Sarfos
11
4560 South Decatur Blvd., Suite 300
PAUL PADDA LAW, PLLC
limited travel outside the United States given the compelling circumstances identified in this
12
13 Stipulation. The parties, however, do recognize that the decision to modify the Sarfos’
Las Vegas, Nevada 89103
14 conditions of travel rests exclusively with the Court.
15 Pretrial services has previously advised undersigned counsel for Rose Sarfo that it does
Tele: (702) 366-1888 • Fax (702) 366-1940
16
not normally take a position on such requests unless the Court specifically invites a
17
recommendation from pretrial services.
18
19 In light of the foregoing, the Sarfos respectfully request that the Court modify their
20 conditions of release to permit travel to Ghana for the period February 11, 2026 through March
21
31, 2026. Dr. and Mrs. Sarfo understand that, should the Court grant this request, the prior
22
conditions of release would be reinstated upon their return to Las Vegas. Should the Court
23
24 approve this request, the Sarfos respectfully request that the Court direct pretrial services to
25 return their passports to them on or before February 10, 2026. Dr. and Mrs. Sarfo will return
26 their passports to pretrial services upon their return to their home in Las Vegas.
27
28
2
Case 2:23-cr-00132-APG-EJY Document 189 Filed 02/06/26 Page 3 of 3
For the reasons set forth in this joint Stipulation, the parties respectfully request that the
1
2 Court approve this Stipulation.
3 DATED this 5th day of February 2026.
4
Respectfully submitted,
5
6 /s/ Kwame Manley
7 /s/ Kyle Crawford __________________________
__________________________ Kwame Manley, Esq.
8 Kyle Crawford, Esq. Robert Draskovich, Esq.
Andrew Tyler, Esq. Counsel for Dr. Kofi Sarfo
9 Counsel for the United States
10
/s/ Paul S. Padda
11 __________________________
4560 South Decatur Blvd., Suite 300
PAUL PADDA LAW, PLLC
Paul S. Padda, Esq.
12 Counsel for Rose Sarfo
13
Las Vegas, Nevada 89103
14
IT IS SO ORDERED:
15
The parties’ Stipulation is approved to permit Dr. Kofi
Tele: (702) 366-1888 • Fax (702) 366-1940
16
Sarfo and Rose Sarfo to travel to Ghana on February
17 11, 2026 and return to the United States on or before
March 31, 2026. Pretrial Services shall provide Dr.
18
and Mrs. Sarfo their United States passports on or
19 before February 10, 2026. Dr. and Mrs. Sarfo shall
return their passports to pretrial services upon their
20 return to Las Vegas.
21
22 __________________________________________
UNITED STATES DISTRICT JUDGE
23
24
25 DATED: February 6, 2026
26
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