Case 3:23-cr-00118-GC Document 18 Filed 08/07/23 Page 1 of 2 PageID: 139
`Case 3:23-cr-00118-GC Document 18 Filed 08/07/23 Page 1 of 2 PagelD: 139
`
`Sills Cummis & Gross
`A Professional Corporation
`
`The Legal Center
`One Riverfront Plaza
`Newark, New Jersey 07102
`Tel: (973) 643-7000
`Fax (973) 643-6500
`
`Richard J. Sapinski
`Memberof the Firm
`
`(973) 643-5975
`Direct Dial:
`E-mail: rsapinski@sillscummis.com
`
`August 7, 2023
`
`VIA EMAIL
`Magistrate Judge Douglas E. Arpert
`ClarksonS. Fisher Building & U.S. Courthouse
`402 East State Street Room 2020
`Trenton, NJ 08608
`dea_orders@njd.uscourts.gov
`
`Re:
`
`United States v. Sahni, Cr. No. 23-118 (GC):
`Requested Modification of Dates of Travel
`
`101 Park Avenue
`28% Floot
`New York, NY 10178
`Tel: (212) 643-7000
`Fax: (212) 643-6300
`
`Dear Judge Arpert:
`
`On August 1, 2023 my partner Joseph Shumofksy wrote to Your Honorrequesting
`permission for Dr. Sahni to travel to Greece to attend her brother’s birthday celebration and
`accompany another brother to several medical appointments in Greece. Your Honor granted that
`motion on August 3. It was contemplated at the time Dr. Sahni and her husband wouldtravel to
`Greece on August 9 and return on August 23. However, Dr. Sahni advises that the airline tickets
`for those dates are no longer available and that the available dates are leaving August 13 and
`returning August 30.
`
`WhenDr. Sahni wentto the probationoffice to get her passport she was advised that she
`neededa revised order in order for probation to release the passport. I respectfully request that
`Your Honor enter the revised order as written below.
`
`I have copied AUSA Sophie Reiter and Pretrial Services officer Todd Jones onthis letter
`request. It is my understanding that Mr. Jones is aware and doesnot object to the revised order,
`and I have emailed AUSA Reiter. I assumeshe likewise will have no objection, but I have not
`heard from her directly. However, because of the short time frame involved, I am makingthis
`request at this time andwill advise the court if and when I hear from her regarding her position.
`
`9841634 v1
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`Case 3:23-cr-00118-GC Document 18 Filed 08/07/23 Page 2 of 2 PageID: 140
`Case 3:23-cr-00118-GC Document 18 Filed 08/07/23 Page 2 of 2 PagelD: 140
`
`Sills Cummis & Gross
`A Professional Corporation.
`
`August 7, 2023
`Page 2
`
`Thank you for Your Honor’s consideration of this matter.
`
`Respectfully,
`oo,
`
`nohk:
`
`" Ye
`
`RICHARD J. SAPINSKI
`
`RJS/mm
`cc:
`Sophie Reiter, AUSA (via email)
`Todd Jones, PTS (via email)
`
`This Court GRANTSDefendant Harsha Sahni’s Motion Seeking Permission to Travel to
`
`Greece on August 13, 2023 and returning on August 30, 2023. Defendant shall coordinate with
`
`PTSto provide any information requested about her travel to Greece and to report to PTS as
`
`directed throughout the duration of the trip. PTS shall provide the Defendant with her passport,
`
`as needed, for the purposeofthistrip.
`
`SO ORDERED
`
` August 7, 2023
`
`9841634 v1
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`7
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