Case 3:23-cr-00118-GC Document 17 Filed 08/03/23 Page 1 of 2 PageID: 137
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`The Legal Center
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`Joseph B. Shumofsky, Esq.
`Member
`Direct Dial: 973-643-5382
`Email: jshumofsky@sillscummis.com
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`August 1, 2023
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`VIA EMAIL
`Magistrate Judge Douglas E. Arpert
`Clarkson S. Fisher Building & U.S. Courthouse
`402 East State Street Room 2020
`Trenton, NJ 08608
`dea_orders@njd.uscourts.gov
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`Re: United States v. Sahni, Cr. No. 23-118 (GC):
`Motion Seeking Permission to Travel
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`Dear Judge Arpert:
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`We are writing seeking permission for Dr. Harsha Sahni to travel to Greece in mid-
`August. We have contacted both the Government and Pretrial Services (“PTS”) regarding Dr.
`Sahni’s request to travel, and each has consented to Dr. Sahni’s request.
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`On February 16, 2023, Dr. Sahni entered a plea of guilty before Judge Castner, pursuant
`to a plea agreement with the Government. Following the plea hearing, Dr. Sahni appeared before
`Your Honor for a bail hearing, at which You released Dr. Sahni on a $500,000 bond, with
`conditions. See Docket Entry 9. Among the conditions ordered were: (i) Dr. Sahni shall report to
`PTS as directed; (ii) Dr. Sahni’s travel is restricted to the continental United States; and (iii) Dr.
`Sahni shall surrender her passport to PTS. Sentencing is scheduled for September 14, 2023.
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`Dr. Sahni respectfully requests permission to travel to Greece for two weeks in mid-
`August (from approximately August 9 to approximately August 23) to attend one brother’s
`birthday celebration and accompany another brother to several medical appointments. Only Dr.
`Sahni’s husband will be traveling with her; her sons will remain in the United States.
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`If granted permission to travel to Greece in mid-August, Dr. Sahni will coordinate with
`PTS to provide any information requested about her travel to Greece and to report to PTS as
`directed throughout the duration of the trip.
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`Case 3:23-cr-00118-GC Document 17 Filed 08/03/23 Page 2 of 2 PageID: 138
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`Michelle A. Siedzik
`July 21, 2023
`Page 2
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`Thank You for Your Honor’s consideration of this matter.
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`Respectfully,
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`/s/Joseph B. Shumofsky
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`Joseph B. Shumofsky
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`Sophie Reiter, AUSA (via email)
`Todd Jones, PTS (via email)
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`This Court GRANTS Defendant Harsha Sahni’s Motion Seeking Permission to Travel to
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`cc:
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`Greece in mid-August. Defendant shall coordinate with PTS to provide any information
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`requested about her travel to Greece and to report to PTS as directed throughout the duration of
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`the trip. PTS shall provide the Defendant with her passport, as needed, for the purpose of this
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`___________________________
` Douglas E. Arpert
` United States Magistrate Judge
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`trip.
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`SO ORDERED
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`August ___, 2023
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