`
`Case 1:19-cr-00789-PGG Document 341 Filed 01/13/21 Page 1 of 1Case 1:19-cr-00789-PGG Document 342 Filed 01/20/21 Page 1 of 1
`
`LAW OFFICES OF
`NATALI J.H. TODD, P.C.
`
`26 COURT STREET
`SUITE 413
`BROOKLYN, NY 11242-1134
`
`Tel: 718-797-3055
`Fax: 718-504-3900
`E-mail: natali_todd@yahoo.com
`www.natalitoddlawyer.com
`
`NATALI J.H. TODD
`MEMBER: NY & MA BAR
`
`January 13, 2021
`
`By ECF
`Hon. Paul G. Gardephe
`United States District Judge
`Southern District of New York
`40 Foley Square
`New York, NY 10007
`
`Re:
`
`U.S. v. Angela Myers, 19 Cr. 789 (PGG)
`
`January 20, 2021
`
`Dear Judge Gardephe:
`
`I write with the consent of the government and U.S. Pretrial Officer Lea Harmon, to
`respectfully request a modification of the terms and conditions of Ms. Myers’ bail to permit her to
`reside in Stroudsburg, PA, and Brooklyn, NY, thereby extending her permissible districts of travel
`to include Pennsylvania. Ms. Myers has secured a residence in Stroudsburg, PA but will alternate
`between her Brooklyn home and the Pennsylvania home weekly because her children are enrolled
`in school in Brooklyn. Additionally, the children’s father resides in Brooklyn and it is necessary that
`they continue to have a relationship with him.
`
`The home address in Pennsylvania was provided to pretrial officer Lea Harmon. Ms. Myers
`will continue to abide by all other bail conditions. Thank you for your consideration to this request.
`
`Respectfully,
`
`/s/ N. Todd
`Natali Todd, Esq.
`Attorney for Angela Myers
`
`cc: PTSO Lea Harmon (by email)
` AUSA Mathew Andrews (by email)
` AUSA Louis Pelligrino (by email)
`
`

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