`
`Case 1:19-cr-00789-PGG Document 865 Filed 05/20/22 Page 1 of 1Case 1:19-cr-00789-PGG Document 868 Filed 05/23/22 Page 1 of 1
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`A N T H O N Y L . R I C C O
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`t o n y r i c c o @ a o l . c o m
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`May 20, 2022
`
`Honorable Paul G. Gardephe
`United States District Judge
`Southern District of New York
`40 Foley Square
`New York, NY 10007
`
`Dated: May 23, 2022
`
`Re: United States v. Latifah Abdul-Khaliq, Docket No. 19 Cr. 789 (PGG)
`
`Dear Judge Gardephe:
`
`The purpose of this letter motion is to request a modification of defendant
`Latifah Abdul-Khaliq’s conditions of pretrial release, to permit her to travel from
`her present residence, located at 5400 Montbrook Circle, Apt. A, Richmond,
`Virginia, to Durham, North Carolina, so that she may visit with her son, Mustafa
`Abdul-Khaliq, one last time prior to her scheduled BOP surrender date of June 10,
`2022.
`
`If this application is granted, Latifah Abdul-Khaliq would travel by car and
`stay at the home of her friend, Anthony Beiser, which is located at 2234 Holly
`Hill Drive, Durham, North Carolina. Additionally, she would be reachable by cell
`phone at all times during her travel.
`
`and Pretrial Services Officer Francesca
`A.U.S.A. Louis Pellegrino
`Tessier-Miller have been informed of counsel’s intention to file this application,
`and neither has any objection.
`
`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
`
`cc: A.U.S.A. Louis Pellegrino (By E.C.F.)
`
`

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