Notice of Motion — No. 1:22-cr-00042 (Dkt. 13, W.D.N.Y.)

Summary

A Notice of Motion, Document 13 filed June 14, 2022 in the Western District of New York (Case 1:22-cr-00042-JLS-JJM, Cri. No. 22-CR-42-JLS-JJM), United States v. John L. Hutchins and Roberto Soliman, made by Rodney O. Personius of Personius Melber LLP for defendant Roberto Soliman. It seeks permission for out-of-state travel by Mr. Soliman between June 18 and June 20, 2022, with oral argument not requested. The declaration of counsel says he is on pretrial release with a condition against leaving the district without court permission, and plans to travel by automobile with a cousin and her husband to the Washington, DC area, returning Monday, June 20, 2022. It states that the probation officer has no opposition and the Assistant U.S. Attorney defers to the officer.

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      Case 1:22-cr-00042-JLS-JJM Document 13 Filed 06/14/22 Page 1 of 4




UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF NEW YORK
___________________________________

UNITED STATES OF AMERICA
                                                NOTICE OF MOTION
                           Plaintiff,
                                                Cri. No. 22-CR-42-JLS-JJM
v.

JOHN L. HUTCHINS & ROBERTO SOLIMAN

                        Defendants.
___________________________________

      PLEASE TAKE NOTICE:

MOTION MADE BY:                          Rodney O. Personius
                                         PERSONIUS MELBER LLP
                                         Attorney for Defendant
                                         ROBERTO SOLIMAN

DATE, TIME & PLACE:                      Oral argument is not requested

RELIEF SOUGHT:                           Permission for out-of-state travel by
                                         defendant Soliman between June 18 and
                                         June 20, 2022

GROUNDS FOR RELIEF SOUGHT:               Discretion of the Court

SUPPORTING PAPERS:                       Annexed Declaration of Counsel




Dated: Buffalo, New York
       June 14, 2022
                                         /s/ Rodney O. Personius
                                         Rodney O. Personius, Esq.
                                         PERSONIUS MELBER LLP
                                         Attorneys for Defendant
                                         ROBERTO SOLIMAN
                                         2100 Main Place Tower
                                         Buffalo, NY 14202
                                         (716) 855-1050
                                         rop@personiusmelber.com
      Case 1:22-cr-00042-JLS-JJM Document 13 Filed 06/14/22 Page 2 of 4




TO:   AUSA Paul Bonnano
      United States Attorney’s Office
      Western District of New York
      Buffalo, New York 14202


      USPO Andre McCray
      United States Probation Office
      2 Niagara Square
      Buffalo, New York 14202


      Paul Cambria, Esq.
      Justin Ginter, Esq
      Lipsitz Green Scime Cambria LLP
      42 Delaware Ave. #120
      Buffalo, New York 14202
        Case 1:22-cr-00042-JLS-JJM Document 13 Filed 06/14/22 Page 3 of 4




UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF NEW YORK
___________________________________

UNITED STATES OF AMERICA
                                                              DECLARATION OF COUNSEL
                               Plaintiff,
                                                              Cri. No. 22-CR-42-JLS-JJM
v.

JOHN L. HUTCHINS & ROBERTO SOLIMAN

                        Defendants.
___________________________________


     RODNEY O. PERSONIUS declares the truth of the following under the penalty of perjury:

        1.     I am a member of Personius Melber LLP, attorneys for Defendant Roberto Soliman.

        2.     Mr. Soliman is currently on pre-trial release, which includes a condition at

paragraph 8(i) of the Order Setting Conditions of Release that he not leave the district absent court

permission.

        3.     The defendant’s cousin, Sandra Adly, and her husband, Jack, reside at 389 Quarry

Run, Grand Island, NY 14072.

        4.     Mr. Soliman seeks permission of the Court to travel with the Adlys to Washington,

DC over the upcoming weekend.

        5.     In particular, their plan is to leave Western New York on Saturday morning, June

18, 2022, by automobile.

        6.     While in the Washington, DC area, their intention is to stay at the Double Tree

Hilton Hotel, 300 Army Navy Dr., Arlington, VA 22202-2891.

        7.     Mr. Soliman, his cousin, and her husband will then return by motor vehicle to

Western New York on Monday, June 20, 2022.
       Case 1:22-cr-00042-JLS-JJM Document 13 Filed 06/14/22 Page 4 of 4




       8.      United States Probation Officer Andre McCray, who supervises the

defendant's pretrial release, has no opposition to this requested travel.

       9.      Assistant United States Attorney Paul Bonanno defers to the judgment of

USPO McCray regarding this requested out-of-state travel.



       WHEREFORE, application is hereby made for approval by the Court of out-of-state travel

by defendant Roberto Soliman to Washington, DC and Arlington, VA between June 18 and June

20, 2022.



Dated: Buffalo, New York
       June 14, 2022


                                                       /s/ Rodney O. Personius
                                                       Rodney O. Personius


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