USA v. Hernandez, 1:18-cr-00420, No. 247 (S.D.N.Y. Mar. 5, 2019)

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Exhibits:

USA v. Hernandez, 1:18-cr-00420, No. 247 (S.D.N.Y. Mar. 5, 2019)

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Case 1:18-cr-00420-ALC Document 247 Filed 03/05/19 Page 1 of 2
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`BENJAMIN ZEMAN ZEMAN & WOMBLE, LLP
`KEN WOMBLE ATTORNEYS AT LAW
`66 WILLOUGHBY STREET, 2ND FLOOR
`BROOKLYN, NEW YORK 10007
`(718) 514-9100 · FAX (917) 210-3700
`WWW.ZEMANWOMBLELAW.COM
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`March 5, 2019
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`VIA ECF & E-MAIL
`Hon. Andrew L. Carter
`United States District Judge
`Thurgood Marshall United States Courthouse
`40 Foley Square
`New York, NY 10007
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`Re: United States v. Llanes, 18 Cr. 420 (ALC)
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`Dear Judge Carter:
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`I represent Tito Llanes in the above-referenced matter and submit this letter requesting a
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`modification of my client’s bail conditions.
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`Mr. Llanes is currently under GPS monitoring ordered by Magistrate Judge Ona T. Wang
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`following a bail hearing held on December 4, 2018. Since that date, Mr. Llanes has been
`compliant with the conditions of his release. In addition, Mr. Llanes has obtained employment
`with the New York City Parks Department (see attached pay stub, Exhibit A). In conjunction
`with his employment, Mr. Llanes has earned his CPR certification through the American Red
`Cross (see CPR certification, Exhibit B) as well as his OSHA Card (see Exhibit C). Finally, Mr.
`Llanes has taken advantage of an opportunity presented by the NYC Parks Opportunity
`Program’s Education Department and has enrolled in High School Equivalency classes (see
`attached Parks letter, Exhibit D).
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`Mr. Llanes’ current work schedule is Mondays, Wednesdays and Fridays, from 7am until
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`3:30pm. His current class schedule is Tuesdays and Thursdays, from 9am until 3:00pm.
`Accordingly, I request that Mr. Llanes’ bail conditions be modified from GPS monitoring to a
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`Case 1:18-cr-00420-ALC Document 247 Filed 03/05/19 Page 2 of 2
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`The government has been consulted and does not consent to this request.
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`Thank you for your consideration of this request.
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`curfew that would allow him to leave his home in time to get to work/classes, and require that he
`return home at a reasonable hour to be determined by the Court.
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`CC: AUSA Jacob Warren
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`Respectfully,
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`/s/ Arthur Ken Womble
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