`LAW OFFICES
`JOHN S. WALLENSTEIN
`1100 Franklin Avenue
`Garden City, New York 11530
`(516) 742-5600 Fax (516) 742-5040
`Email: JSWallensteinEsq@outlook.com
`
`May 27, 2022
`
`Re: United States v. Elvin Baghir-Pur
`
`Docket # S15 18 CR 509 (GBD)
`
`BY ECF
`Hon. George B. Daniels
`United States District Judge, SDNY
`500 Pearl Street
`New York, New York 10007
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`Dear Judge Daniels;
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`I write to respond to the Government’s opposition (ECF # 784) to Mr. Baghir-
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`Pur’s request for a modification of the terms of his release. I understand the
`Government’s concerns, but I respectfully suggest that it is possible for the Court to
`order him to report to the embassy on a regular schedule, and certainly to report
`remotely to Probation from Azerbaijan. Government agencies cooperate with each
`other all the time, and while it is no doubt true that the Department of State has
`nothing to do with the Courts, it is not a great burden for a consular officer or other
`embassy employee to send an email to Probation when my client reports,
`acknowledging that fact. The logistics are not complex. My client is certainly willing
`to abide by whatever conditions the Court or probation would impose upon him, and
`as noted he has been in full compliance thus far.
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`The Government did not address one of the key issues raised in my
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`application, which is Mr. Baghir-Pur’s chronic asthma condition and susceptibility
`to COVID-19, the rate of which, as the Court knows, is increasing dramatically. His
`physician suggests a change of climate, and the request we make would afford him
`a safer environment, given his medical issues. Certainly he should not be forced to
`jeopardize his health if there is an alternative.
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`Case 1:18-cr-00509-GBD Document 785 Filed 05/31/22 Page 2 of 2
`LAW OFFICES
`JOHN S. WALLENSTEIN
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`We respectfully urge the Court to grant the application. Thank you for your
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`courtesy and consideration.
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`Respectfully yours,
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`/S/John S. Wallenstein
`JOHN S. WALLENSTEIN
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