Pandemic Darlings The pandemic economy, in original documents
Home Source documents Letter to Judge Kaplan, June 16, 2023, Re: United States v. Heaven West, 21 Cr. 729 (LAK) (Dkt. 89, S.D.N.Y.)

Letter to Judge Kaplan, June 16, 2023, Re: United States v. Heaven West, 21 Cr. 729 (LAK) (Dkt. 89, S.D.N.Y.)

Summary

A letter dated June 16, 2023 from defense attorney Emilee A. Sahli of Sahli Law, PLLC to Judge Lewis A. Kaplan of the U.S. District Court for the Southern District of New York in United States v. Heaven West, 21 Cr. 729 (LAK). It asks the Court to modify a bail condition that bars West from possessing personal identifying information of others, so that West can handle job applicants' identification documents as her current job now requires. The filing includes a June 16, 2023 letter from Assistant U.S. Attorney Michael D. Neff stating that the government has no objection. The letter bears a memo endorsement, 'Application granted on consent of the Government', signed by Judge Kaplan and dated June 21, 2023.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Full text

Text recognized from a scanned document; may contain errors.

Case 1:21-cr-00729-LAK Document 89 Filed 06/24/23 Page 1 of 2

SAHLI LAW, PLLC
SAHLI 195 BROADWAY, 4" FLOOR
LAW,PLLC BROOKLYN, NY 11211

LAW & TECH PH: 347-378-8132
wWww.SAHLILAW.COM

June 16, 2023

VIA ECF

Hon. Lewis A. Kaplan
United States District Judge
Daniel Patrick Moynihan

MEMO ENDORSED

Application granted on consent of the

United States Courthouse Government.
500 Pearl Street
New York, NY 10007 So Ordered: /s/

Hon. Lewis A. Kaplan, U.S.D.J.
Dated: 6/21/2023

RE: United States v. Heaven West, 21 Cr. 729 (LAK)
Dear Judge Kaplan:

| represent Heaven West in the above-referenced matter. | request an adjustment of Ms. West’s bail
conditions to allow her to possess personal identifying information of others as required by her current
employment responsibilities.

Ms. West has the following bail conditions:
e Def. may not possess personal identifying information of others or create fraudulent
documents.

Ms. West’s current employment has expanded her responsibilities to include obtaining identification
documents of job applicants, making copies of these documents, entering identification information into
the employer’s database, then returning the identification documents to the job applicants.

The Defense requests that the Court modify the conditions of her bail to allow Ms. West to possess
personal identifying information for the sole purpose of her current job responsibilities. This
modification will allow Ms. West to continue her employment. The Government does not object to this
request.

Please contact me if you have any questions or concerns.
Very truly yours,

/s/ Emilee Sahli
Emilee A. Sahli, Esq.

CC: Michael Neff, Assistant United States Attorney (via email)
Marlon G. Kirton, Esq. (via email)

SAHLI LAW, PLLC, 195 BROADWAY, 4™ FLOOR, BROOKLYN, NY 11211
PH: 347-378-8132 | www.SAHLILAW.COM
Case 1:21-cr-00729-LAK Document 89 Filed 06/21/23 Page 2 of 2
U.S. Department of Justice

United States Attorney
Southern District of New York

The Silvio J. Mollo Building
One Saint Andrew’s Plaza
New York, New York 10007

June 16, 2023
BY EMAIL

The Honorable Lewis A. Kaplan

United States District Judge

Southern District of New York

Daniel Patrick Moynihan U.S. Courthouse
500 Pearl Street

New York, New York 10007

Re: United States v. Heaven West,
21 Cr. 729 (LAK)

Dear Judge Kaplan:

This afternoon, defendant Heaven West filed a bail modification motion, requesting that
she be permitted to possess the personal identifying information of other individuals for the sole
purpose of her current job responsibilities. (Dkt. 88). The Government has no objection to this
request. Please let us know if anything further would be useful.

Respectfully submitted,

DAMIAN WILLIAMS
United States Attorney for the
Southern District of New York

de 4 f a
Michael D. Neff ~
Assistant United States Attorney

(212) 637-2107

cc: Marlon Kirton, Esq. (via email)


File and source

File
gov.uscourts.nysd.571082.89.0.pdf
Size
306,456 bytes
SHA-256
fd5ccc0b3fc56382a27db3bcd8c2c1ae020ea3f98b75a64b222a677cec261db1
Our copy
gov.uscourts.nysd.571082.89.0.pdf
Original
archive.org
Back to top