`Case 1:19-cr-00789-PGG Document 853 Filed 05/03/22 Page 1 of 2Case 1:19-cr-00789-PGG Document 856 Filed 05/06/22 Page 1 of 2
`A N T H O N Y L . R I C C O
`A T T O R N E Y A T L A W
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`2 0 V E S E Y S T R E E T C S U I T E 4 0 0
`N E W Y O R K , N E W Y O R K 1 0 0 0 7
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`T E L ( 2 1 2 ) 7 9 1 - 3 9 1 9
`F A X ( 2 1 2 ) 9 6 4 - 2 9 2 6
`t o n y r i c c o @ a o l . c o m
`
`May 3, 2022
`
`Honorable Paul G. Gardephe
`United States District Judge
`Southern District of New York
`40 Foley Square
`New York, NY 10007
`
`May 6, 2022
`Re: United States v. Latifah Abdul-Khaliq, Docket No. 19 Cr. 789 (PGG)
`
`Dear Judge Gardephe:
`
`The purpose of this letter is to request a modification of defendant Latifah
`Abdul-Khaliq’s conditions of pretrial release, to permit her to temporarily relocate
`from her present residence in Brooklyn, New York, to her mother’s home in
`Richmond, Virginia, until June 10, 2022, which is the date that she is scheduled to
`self surrender at FPC Alderson, which is located in Alderson, West Virginia.
`
`just
`This modification is being requested, because Latifah Abdul-Khaliq
`recently learned that her roommate will be vacating her present residence, and
`Latifah Abdul-Khaliq cannot sustain the rent by herself. Moreover, Latifah Abdul-
`Khaliq would like to move all of her possessions to her mother’s home to be
`stored during the period of her imprisonment. Finally, Alderson, West Virginia is
`closer and more convenient to travel to from Richmond, Virginia than Brooklyn,
`New York.
`
`If this application is granted, Latifah Abdul-Khaliq would reside at the
`home of her mother, which
`is
`located at 5400 Montbrook Circle, Apt. A,
`Richmond, Virginia, and would be reachable by cell phone at all times.
`
`A.U.S.A. Louis Pellegrino has been informed of counsel’s intention to file
`this application, and does not have any objection on behalf of the government.
`
`Thank you for your Honor’s consideration of this application. If there are
`any questions, or if additional information is required, please contact me at your
`Honor’s convenience.
`
`Respectfully,
`
`Anthony L. Ricco
`
`
`
`
`
`Case 1:19-cr-00789-PGG Document 853 Filed 05/03/22 Page 2 of 2Case 1:19-cr-00789-PGG Document 856 Filed 05/06/22 Page 2 of 2
`
`cc: A.U.S.A. Louis Pellegrino (By E.C.F.)
`
`

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