Case 1:18-cr-00509-GBD Document 602 Filed 06/29/20 Page 1 of 1
`U.S. Department of Justice
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`United States Attorney
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`Southern District of New York
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`The Silvio J. Mollo Building
`One Saint Andrew’s Plaza
`New York, New York 10007
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`June 29, 2020
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`Re: United States v. Mishel Levinski, 18 Cr. 509 (GBD)
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`BY ECF
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`The Honorable George B. Daniels
`United States District Judge
`Southern District of New York
`United States Courthouse
`500 Pearl Street, Courtroom 11A
`New York, New York 10007
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`Dear Judge Daniels:
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`The Government writes briefly to clarify its position with respect to defendant Mishel
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`Levinski’s June 25, 2020 letter requesting modification of certain bail conditions to allow overseas
`travel. Mr. Mirvis, counsel for the defendant, accurately conveyed that the Government did not
`offer its consent to the proposed modification. Though the Government has previously consented
`to similar requests for modifications (See, e.g., Dkt. 210, 298, 365, 434, 452, 466, 474, and 487),
`the Government notes each of those requests predated the COVID-19 pandemic and the
`implications the virus has raised for overseas travel. The Government notes that the European
`Union, where the defendant proposes to travel, appears prepared on July 1 to bar U.S.-based
`travelers from entry due to concerns related to COVID-19. (See, e.g., E.U. Plans to Bar Most U.S.
`Travelers When Bloc Reopens at https://www.nytimes.com/2020/06/26/world/europe/europe-us-
`travel-ban.html, last accessed June 29, 2020). Even if the defendant were admitted to Germany
`after traveling there, the state of the global response to the COVID-19 pandemic is such that
`additional travel restrictions may be imposed with little notice, potentially leaving the defendant
`beyond the reach of the Court for an indefinite period of time. At bottom, however, the
`Government believes the proposed modification to be unnecessary and particularly fraught given
`the state of the COVID-19 pandemic and therefore opposes the defendant’s application for
`modification.
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`Respectfully submitted,
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` By: _____________________________
` Matthew J.C. Hellman / Emily A. Johnson
`/ Daniel G. Nessim
` Assistant United States Attorneys
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`(212) 637-2278/ -2409 / -2486
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`cc: Tony Mirvis, Esq., counsel for the defendant Mishel Levinski (via e-mail and ECF)
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