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Motion for Permission to Travel Out of State — No. 3:22-cr-00033 (Dkt. 311, D. Conn.)

Summary

A Motion for Permission to Travel Out of State dated May 12, 2023 in the District of Connecticut (Criminal No. 3:22-cr-00033-OAW), United States v. Michael Dimassa, filed by John R. Gulash of Gulash & Associates, LLC. The defendant, who pleaded guilty on November 1, 2022 to Counts 1, 3 and 5 charging three violations of 18 U.S.C. § 1349 and is scheduled for sentencing May 31, 2023, asks to fly to Texas on May 22, 2023 and return May 23, 2023. His wife and co-defendant Lauren Knox is due to self-surrender to a BOP facility in Texas on May 23, 2023, and the motion says she is pregnant. The government and the probation officer defer to the Court.

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Cite this document

“Motion for Permission to Travel Out of State — No. 3:22-cr-00033 (Dkt. 311, D. Conn.).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/motion-for-permission-to-travel-out-of-state-no-3-22-cr-00033-dkt-311-d7c0340d64/, SHA-256 b0a4480d754fd9f4356ba7feb6b4d6a514d2c8023169f9dd6c43e67a5ba74b36.

Full text

                             UNITED STATES DISTRICT COURT
                               DISTRICT OF CONNECTICUT


UNITED STATES OF AMERICA                      :       CRIMINAL NO.3:22-cr-00033-OAW

                V.                            :

MICHAEL DIMASSA                               :       MAY 12, 2023

                MOTION FOR PERMISSION TO TRAVEL OUT OF STATE


       Defendant MICHAEL DIMASSA hereby moves that he be permitted to travel out of

State to Texas by air beginning May 22, 2023 and returning May 23, 2023 based upon the

following:

       1. On November 1, 2022, Mr. Dimassa pleaded guilty to Counts 1,3 and 5 of the

             Indictment charging three violations of 18 U.S.C §1349.

       2. Mr. DiMassa’s sentencing is currently scheduled for May 31, 2023.

       3. A condition of his release provides that he not leave the State of Connecticut without

             advance approval of his probation officer.

       4. His wife Lauren Knox is a co-defendant in this matter and is scheduled to self-

             surrender to a BOP facility in Texas on May 23, 2023 to begin her sentence imposed

             by this Court. Ms. Knox is pregnant and desires to travel with her husband Mr.

             Dimassa for health and safety reasons.

       5. Defendant Dimassa and Ms. Knox will depart Bradley International Airport in

             Connecticut on May 22, 2023 for Ft Worth, TX and Mr Dimassa will return to

             Bradley on May 23, 2023.

       6. The Government defers to the Court on this Motion.
       7. Undersigned counsel spoke to Probation Officer Nielvis Gonzalez-Perez and he states

             he will defer to the Court and is available for any questions regarding pretrial

             services.




       WHEREFORE, undersigned counsel for Mr. DiMassa requests permission to.travel as

requested.

                DEFENDANT,
                MICHAEL DIMASSA,

                /s/ John R. Gulash__________
                        JOHN R. GULASH, ESQ.
                        GULASH & ASSOCIATES, LLC
                        PO BOX 999
                        265 GOLDEN HILL STREET
                        BRIDGEPORT, CT 06601
                        EMAIL JRGulash@gulashlaw.com
                        TEL 203-870-9944
                        FAX 203-870-9838
                        Fed Bar# ct05093
                                       CERTIFICATION

        I hereby certify that on this date, a copy of the foregoing was filed electronically and
served by mail on anyone unable to accept electronic filing. Notice of this filing will be sent by
email to all parties by operation of the Court’s electronic efile system, or by mail to anyone
unable to accept electronic filing, per indication on the Notice of Electronic Filing. Parties may
access this filing through the Court’s CM/ECF system.




                                            /s John R. Gulash__________
                                            JOHN R. GULASH
                                            GULASH & ASSOCIATES, LLC
                                            PO BOX 999
                                            265 GOLDEN HILL STREET
                                            BRIDGEPORT, CT 06601
                                            EMAIL JRGulash@gulashlaw.com
                                            TEL 203-870-9944
                                            FAX 203-870-9838
                                            Fed Bar# ct05093

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