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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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Cite this document

“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
                                                             27
                                                             28


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