`
`THE LAW FIRM OF
`
`CÉSAR DE CASTRO, P.C.
`
`ATTORNEY AT LAW
`
`MEMORANDUM ENDORSED
`
`December 21, 2022
`
`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
`
`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
`
`USDC SDNY
`DOCUMENT
`ELECTRONICALLY FILED
`DOC #:
`
`
`
`12/22/2022
`
`DATE FILED:
`
`
`Re: United States v. Christopher Santos, 22 Cr. 522 (GHW)
`
`Dear Judge Woods,
`
`We write, with the consent of the government and Pretrial Services, to request a modification of
`Mr. Santos’s bail conditions to include a curfew rather than home detention, and permit him to
`obtain employment. Currently, the conditions of Mr. Santos’s release only allow him to leave
`his home for dialysis, other medical appointments, and to meet with counsel. Mr. Santos would
`like to use his time on Pretrial Supervision productively and seek and obtain employment. As
`noted above, both the government and Pretrial Services consent to this request with the caveat
`that Mr. Santos not obtain overnight employment.
`
`Accordingly, we respectfully request that the court modify Mr. Santos’s conditions of release to
`permit him to seek and obtain employment and that his home confinement be replaced with a
`curfew (the hours decided at the discretion of Pretrial Services).
`
`Respectfully submitted,
`
`/s/
`
`César de Castro
`
`Application denied. This application provides insufficient justification
`for the proposed modification of the conditions of Mr. Santos's pretrial release.
`The application appears not to describe accurately the conditions of Mr. Santos's
`pretrial release. Counsel states that "the conditions of Mr. Santos's release only
`allow him to leave his home for dialysis, other medical appointments, and to
`meet with counsel." This representation to the Court seems to be inconsistent
`with the release conditions described in Dkt. No. 4 at ECF page 5.
`The Clerk of Court is directed to terminate the motion pending at Dkt. No. 15.
`cc: All Parties (via ECF)
`SO ORDERED.
`Dated: December 22, 2022
`New York, New York
`
`
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