`UNITED STATES OF AMERICA,
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` Elvin Baghir-Pur,
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`Defendant.
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`Case 1:18-cr-00509-GBD Document 673 Filed 12/03/20 Page 1 of 3
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`UNITED STATES DISTRICT COURT
`FOR THE SOUTHERN DISTRICT OF NEW YORK
`
`Plaintiff,
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`
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`v.
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`
`
`Case No. 18–cr-509-2 (GBD)
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`
`MOTION TO MODIFY
`CONDITIONS OF RELEASE
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`)
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`__________________________________________________
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`Defendant Elvin Baghir-Pur, by and through his
`
`
`attorney Arkady Bukh, hereby files this motion to modify his
`conditions of release by removing electronic monitoring, and in
`support states as follows:
`
`
`On August 22, 2018, this Court set conditions of
`release of the defendant. ECF No. 100. According to the
`conditions, Defendant is subject to electronic monitoring. Id.
`at 4.
`Mr. Elvin Baghir-Pur has fully complied with all his
`
`
`conditions of release. Mr. Elvin Baghir-Pur is a nonviolent,
`young adult, 24 years of age. He is charged with wire fraud, in
`violation of 18 U.S.C. 1348 and money laundering, in violation
`of 18 U.S.C. 1956. Specifically, he is charged with
`participation, among other members of the conspiracy, in placing
`on internet websites advertisements for the sale of various
`
`
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`Case 1:18-cr-00509-GBD Document 673 Filed 12/03/20 Page 2 of 3
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`high-value goods.
`
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`The Bail Reform Act (the "Act"), 18 U.S.C. §§ 3141-
`3150, authorizes a district court to approve the modification of
`pretrial release conditions mindful of the factors set forth in
`18 U.S.C. 3142(g) that such conditions would reasonably assure a
`defendant's appearance at trial and the safety of the community.
`See 18 U.S.C. § 3142(c)(3)("The judicial officer may at any
`time amend the order to impose additional or different
`conditions of release.").
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`Removing the ankle monitor off the defendant does not
`heighten any risk of flight. However, if not removed, the
`bracelet presence would unreasonably and unjustifiably interfere
`with his education, work, and life, especially in light of the
`Covid-19 pandemic. Specifically, he has problems with finding a
`job as potential employers summarily reject him once they
`observe the bracelet.
`
`
`
`As such, Mr. Elvin Baghir-Pur respectfully requests
`that this court modify his condition of release by removing
`electronic monitoring condition. All other conditions of release
`will remain in effect.
`
`
`The Government does not oppose this request. The
`Pretrial Services Office does not hold a position in regard to
`the request. The Defendant sought the same relief in March of
`2019, and this Court denied his request with respect to removal
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`2
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`Case 1:18-cr-00509-GBD Document 673 Filed 12/03/20 Page 3 of 3
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`of electronic monitoring via GPS. Dkt. 253. Because Defendant
`has been compliant with all other terms and conditions of
`release for more than a year and a half since March of 2019, the
`Defendant respectfully reiterates his request.
`
`
`WHEREFORE, for the reasons set forth herein, Defendant
`requests the Court modify his conditions of release by removing
`his electronic monitoring, and for any further relief the Court
`deems just and proper.
`Date: December 3, 2020
`Respectfully submitted,
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`/s/ Arkady Bukh, Esq.
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` ______________________________
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`Arkady Bukh, Esq.
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`Bukh Law Firm PLLC
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`1123 Avenue Z
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`Brooklyn, NY 11235
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`Phone: (718) 376-4766
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`honorable@usa.com
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`Attorneys for Elvin Baghir-Pur
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`
`
`TO:
`
`Mohammed Ahmed
`U.S Pretrial Services Officer
`Southern District of New York
`Mohammed_Ahmed@nyspt.uscourts.gov
`
`Matthew Jo Chamberlin Hellman
`U.S. Attorney's Office, SDNY (St Andw's)
`One St. Andrew's Plaza
`New York, NY 10007
`(212)-637-2278
`Email: matthew.hellman@usdoj.gov
`
`
`
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`3
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`
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