`
`Case 1:19-cr-00789-PGG Document 372 Filed 04/08/21 Page 1 of 1Case 1:19-cr-00789-PGG Document 373 Filed 04/09/21 Page 1 of 1
`
`Donald D. duBoulay
` Attorney at Law
`
`Telephone: (212) 966-3970
`Fax: (212) 941-7108
`E-mail: dondubesq@aol.com
`
`The Honorable Paul G. Gardephe
`United States District Judge
`Southern District of New York
`Thurgood Marshall Courthouse
`40 Foley Square
`New York, New York 10007
`
`Re: United States v. Graciela Borrero
`19 Cr. 789 (PGG)
`
`Dear Judge Gardephe:
`
`305 Broadway, Suite 602
`New York, NY 10007
`
`April 8, 2021
`
`April 9, 2021
`
`I write on behalf of my client Graciela Borrero to respectfully request that the court
`amend the terms of her pretrial release bond to allow her to travel to Puerto Rico to visit her
`elderly mother. If permitted Ms. Borrero would travel on April 21, 2021 and return on April 25,
`2021. She would reside with her family at URB. La Granja, Calle pepita garcel B#2, Caguas PR
`000725
`
`Ms. Borrero was released on a $50,000.00 PRB on November 7, 2019 and she has been
`compliant with all the terms of her bond. Her travel is presently restricted to the Southern and
`Eastern Districts of New York.
`
`The Government and Pretrial officer Courtney DeFeo take no position on this request.
`
`Respectfully submitted,
`/s/
`
`Donald duBoulay
`
`cc: Louis A. Pellegrino, AUSA
` Mathew Andrews, AUSA
` Courtney DeFeo, PTO
`
`

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