Case 1:22-cr-00522-GHW Document 110 Filed 02/27/23 Page 1 of 2
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`THE LAW FIRM OF
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`CÉSAR DE CASTRO, P.C.
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`ATTORNEY AT LAW
`
`The District
`111 Fulton Street - 602
`New York, New York 10038
`631.460.3951 Office
`646.285.2077 Mobile
`646.839.2682 Facsimile
`cdecastro@cdecastrolaw.com
`cdecastrolaw.com
`
`February 24, 2023
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`Via ECF
`
`The Honorable Gregory H. Woods
`United States District Judge
`United States Courthouse
`Southern District of New York
`500 Pearl St.
`New York, New York 10007
`
`2/27/2023
`
`Re: United States v. Christopher Santos, 22 Cr. 522 (GHW)
`
`Dear Judge Woods,
`
`We write to request, with the consent of the government and Pretrial Services, that Mr. Santos’s
`bail conditions be modified to permit Mr. Santos to visit his mother on a schedule set by Pretrial
`Services. This will be crucial for Mr. Santos to be eligible to receive the kidney transplant that
`he desperately needs.
`
`Mr. Santos currently does not have proper functioning kidneys and is awaiting a transplant. As a
`result, he is treated three times a week with dialysis. After attending his dialysis appointments,
`Mr. Santos is left physically drained and unable to cook for himself. The location of his dialysis
`treatments is close to his mother’s residence. Prior to his arrest, following his dialysis treatment,
`he would visit his mother who would cook for him at her house. He would eat and rest and
`return to his home somewhat rested and nourished. With his current restrictions, Mr. Santos is
`unable to visit his mother after his dialysis. He returns home after dialysis extremely fatigued
`and eats whatever is available, usually fast food, which is far from ideal nourishment following
`kidney dialysis.
`
`As noted above, Mr. Santos is currently on a kidney transplant waiting list. To be eligible for a
`donor kidney, a candidate must be healthy enough to receive the kidney. Since his arrest and
`home confinement, Mr. Santos’ health has deteriorated, which is putting his candidacy for
`transplant in jeopardy.
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`Finally, as Mr. Santos was placed on home confinement before any of his co-defendants were
`indicted, his conditions of pretrial release do not preclude him from having contacts with any co-
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`USDC SDNY
`DOCUMENT
`ELECTRONICALLY FILED
`DOC #:
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`DATE FILED:
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`MEMORANDUM ENDORSED
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`Case 1:22-cr-00522-GHW Document 110 Filed 02/27/23 Page 2 of 2
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`defendants. The government requests and the defense consents to a modification that includes
`this condition.
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`Accordingly, we respectfully request that the court modify Mr. Santos’s conditions of release to
`permit him to see his mother after his dialysis treatments on a schedule predetermined by Pretrial
`Services.
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`Respectfully submitted,
`
`/s/
`
`César de Castro
`
` cc: All Parties (via ECF)
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`Application granted. The conditions of Mr. Santos’ pretrial release are modified as follows: Mr. Santos may visit his
`mother following his dialysis treatments on a schedule to be determined by Pretrial Services. In addition, the
`defendant may not have contact with any of his co-defendants. The remaining conditions of Mr. Santos’ pretrial
`release remain in full force and effect.
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`The Clerk of Court is directed to terminate the gavel pending at Dkt. No. 108
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`SO ORDERED.
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`Dated: February 27, 2023
`New York, New York
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`2
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`_____________________________________
` GREGORY H. WOODS
` United States District Judge
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