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Letter on Bail Enlargement — United States v. Alicia Ayers, 21-CR-00440 (S.D.N.Y.), Dkt. 60

Summary

Letter dated January 11, 2022, from Deveraux L. Cannick to Judge Nelson S. Roman, Document 60, filed 01/13/22, in Case 7:21-cr-00440-NSR, requesting a bail enlargement for Alicia Ayers. It states that she requests permission to travel in order to secure business for her travel agency business, and lists planned trips to Baltimore, Maryland on January 15th, 2022; New York to New Orleans on January 18th returning on January 19th; and Newark to Fort Myers on January 20th returning January 23. It states that AUSA Courtney Heavey takes no position and Probation Officer Killian does not object. A notation dated 1/13/2022 states that the request for a temporary bail modification is GRANTED without objection by the Pretrial Services Officer.

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“Letter on Bail Enlargement — United States v. Alicia Ayers, 21-CR-00440 (S.D.N.Y.), Dkt. 60.” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-s-d-n-y-no-7-21-cr-00440-dkt-60-s-d-n-y-8b6df7fbd1/, SHA-256 8d7a217b5aedf147f45fdc00aabf66751977c17ec5aecd6c854664385c2f969c.

Full text

           Case 7:21-cr-00440-NSR Document 60 Filed 01/13/22 Page 1 of 2




                                                                                                1/13/2022




Robert J. Aiello                                                                69-06 Grand Avenue
Deveraux L. Cannick                                                      Maspeth, New York 11378
   ______                                                      (718) 426-0444, Fax (718) 803-9764
                                                                       Email: info@aiellocannick.com
Jennifer Arditi
Of Counsel
       John S. Esposito
       Anthony J. Rattoballi


                                                        January 11, 2022

                                                        Deft's request for a temporary bail modification for the
                                                        below-stated specified dates is GRANTED without
VIA ECF                                                 objection by the Pretrial Services Officer. The Gov't
Honorable Nelson S. Roman
United States District Court
                                                        does not take a position. Deft. shall provide Pretrial
Southern District of New York                           Services with specific travel information. Clerk of
300 Quarropas Street, Chambers 533                      Court requested to terminate the motion (doc. 59).
White Plains, New York 10601-4150                       Dated: Jan. 13, 2022

         Re:      United States v. Alicia Ayers
                  Case No.: 21-CR-00440 -01

Dear Judge Roman:

         We write to request a bail enlargement for Ms. Alicia Ayers. She requests permission to travel
to the following locations in order to secure business for her travel agency business.

         1. Baltimore, Maryland on January 15th, 2022. She will be departing at 7:00 a.m. and returning
            at 7:00 p.m. She will be meeting with Timothy Anderson at 2512 Jefferson Street,
               Baltimore, MD, telephone 443-529-6780. This is a development property that will be
               listed as an Airbnb.

         2. New York to New Orleans on January 18th returning on January 19th. She will be
               visiting an Airbnb located at 2706 Saint Claude Avenue, New Orleans and meeting
               with Lloyd Dillon, telephone 504-251-9555. This is a potential site for new clients.

         3. Newark to Fort Myers on January 20th returning January 23. Newark at 10:50 a.m. returning
            at 8:00 p.m. back to Newark. Hotel – Town Place Suites – 23161 Coconut Point, Fort
            Myers. She will be meeting with Dean Harris, telephone 239-565-5252. This is also
            a development project that will be listed as an Airbnb.
             Case 7:21-cr-00440-NSR Document 60 Filed 01/13/22 Page 2 of 2



                                                   -2-



         At the request of ADA Heavey, we inform the Court that Ms. Ayers has made a total of
three trips for her travel business to date. Ms. Ayers has traveled to the following locations thus far:

        1.    Hawaii – September 26, 2021
        2.    New Orleans – October 30, 2021
        3.    Baltimore – November 18, 2021
        4.    Pennsylvania – December 10, 2021 - cancelled

        Please know that AUSA Courtney Heavey takes no position and Probation Officer Killian does
not object to our request.

        Thank you in advance for your consideration in this matter.



                                                         Respectfully submitted,

                                                         /s/ Deveraux L. Cannick

                                                         Deveraux L. Cannick
DLC/mw

cc: AUSA Courtney Heavey
    AUSA Jeffrey Coffman
    Probation Officer Jessica Killian

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