Letter Re: United States of America v. Juan Nolasco-Martinez, et al., 22-CR-00012 (JPO) & 22-CR-00008 (JPO) (Dkt. 101, S.D.N.Y.)

Summary

A letter dated 12/15/2025 from John L. Russo of J.L. Russo, P.C. to Judge J. Paul Oetken in United States of America v. Juan Nolasco-Martinez, et al., 22-CR-00012 (JPO) & 22-CR-00008 (JPO), filed 12/17/25 as Document 101. It states that Nolasco-Martinez, a U.S. citizen, is serving a term of federal probation after completing the sentence in the case, and asks permission to travel to the Dominican Republic from December 22 to January 5th to visit the defendant's mother. The letter says Nolasco-Martinez has been fully compliant with all conditions of probation and that the government does not oppose: AUSA Patrick Maroney has no objection, AUSA Mitzy Steiner defers to Probation, and Probation Officer Fernandez has no objection. The court's endorsement reads Granted. So ordered. and is dated December 15, 2025.

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Full text

               Case 1:22-cr-00012-JPO         Document 101       Filed 12/17/25      Page 1 of 1

                                            J.L. Russo, P.C.
 JOHN L. RUSSO                      31 · 19 Newtown Avenue, Suite 500                      PARALEGAL
ATTORNEY AT LAW                           Astoria, New York 11102                       Maria Nunez, B.S.
                                            Tel: 718 · 777 · 1277
  COUNSEL                                   Fax: 718 · 204 · 2310
Milton Florez, Esq.                   Email: JLRussoPC@Gmail.com
Michael Horn, Esq.
                                                                                     Granted.
                                                                                     So ordered.
                                                           December 15, 2025         12/15/2025


       Via ECF
       Honorable. J. Paul Oetken
       United States District Court Judge
       Thurgood Marshall
       United States Courthouse
       40 Foley Square
       New York, NY 10007

               Re: United States of America v. Juan Nolasco -Martinez, et al.
                   22-CR-00012 (JPO) & 22-CR-00008 (JPO)

       Your Honor:

                This office represents Defendant Juan Nolasco-Martinez, a U.S. citizen, who is
       currently serving a term of federal probation following the completion of his sentence in
       the above-mentioned matter. I respectfully write to request the Court’s permission for Mr.
       Nolasco Martinez to travel to the Dominican Republic from December 22 nd to January 5th
       to visit his mother.

              Mr. Nolasco Martinez has been fully compliant with all conditions of probation to
       date. He has consistently reported as required, completed all obligations, and demonstrated
       ongoing commitment to abiding by the terms of his supervision.

              The Government does not oppose this request. Specifically, AUSA Patrick Maroney has
       no objection, AUSA Mitzy Steiner defers to Probation, and Probation Officer Fernandez has
       advised that there are no objections to the requested travel.

              Given these circumstances, and considering Mr. Nolasco-Martinez’s record of
       compliance, we respectfully request that the Court grant him leave to travel as outlined
       above. Thank you.

                                                           Respectfully submitted,
                                                           /s/ John L. Russo
                                                           John L. Russo (JR6200)


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