Letter Re: United States of America v. Juan Nolasco-Martinez, et al., Case No.: 22-CR-00012 (JPO) (Dkt. 28, S.D.N.Y.)
Summary
Defense attorney John L. Russo wrote to Judge J. Paul Oetken on December 2, 2022 in United States of America v. Juan Nolasco-Martinez, et al., Case No. 22-CR-00012 (JPO) (S.D.N.Y.), asking the court to remove Nolasco-Martinez's electronic monitoring device as a pretrial release condition, with all other conditions to stay the same. The letter says U.S. Pretrial Services Officer Viosanny Harrison consented and that AUSA Mitzi Steiner deferred to Pretrial Services. The letter adds that release conditions had also been set by Judge Buchwald in case 21-CR-00008 (NRB) and that a companion request was being sent there as well. The letter bears the endorsement "Granted as to case number 22 Cr. 12 (JPO). So ordered." dated 12/12/2022, and was filed as Document 28.
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Case 1:22-cr-00012-JPO Document 28 Filed 12/12/22 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.
December 2, 2022
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.
Case No.: 22-CR-00012 (JPO)
Your Honor:
This office represents, the Defendant Juan Nolasco in the above-referenced matter
which is pending before the Court.
By this letter, the Mr. Nolasco-Martinez respectfully requests the Court’s
consent to a change of his pre-trial release conditions – to wit, the removal of his
electronic monitoring device. All other pre-trial release conditions to stay the same. Ms.
Viosanny Harrison, Mr. Nolasco Martinez’ U.S. Pretrial Services Officer, has specifically
consented to this change of condition and AUSA Mitzi Steiner has deferred to PTS on this
issue. As Mr. Nolasaco-Martinez’ pre-trial release conditions have also been set by Judge
Buchwald in case 21-CR-00008 (NRB), a companion request is being sent to Judge
Buchwald as well.
. The Court’s consideration of this request is greatly appreciated.
Granted as to case number 22 Cr. 12 (JPO).
So ordered. Yours truly,
12/12/2022
John L. Russo
John L. Russo (JR6200)
Cc: USPSO Vioscanny Harrison (via Email)
AUSA Mitzy Steiner(VIA ECF)
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