`LAW OFFICES OF JILL R. SHELLOW
`______________________________________________________________________________
`
`Telephone: 212.792.4911 / Fax: 212.792.4946 / jrs@shellowlaw.com
`15 Chester Avenue, White Plains, New York 10601
`
`September 25, 2023
`
`VIA ECF AND EMAIL
`The Honorable Gregory H. Woods
`United States District Judge
`Southern District of New York
`500 Pearl Street
`New York, NY 10007
`
`9/26/2023
`
`RE: United States v. Santos (Juan Mercedes), 22-cr-522 (GHW)
`
`Dear Judge Woods:
`
`I represent Juan Mercedes in the above-referenced case. Mr. Mercedes has an
`opportunity to interview for a job on Wednesday, September 27, 2023 as a maintenance
`worker at Gym U NYC. Mr. Mercedes is on home incarceration with location monitoring.
`I am writing to request a temporary modification of his bail so that he can attend the
`interview. Pretrial Services does not object to this request, and the officer noted that she has
`been focusing with him on obtaining employment and believes it is important that he be able
`to go to this interview. I have asked the Government for its position on this request, and as
`of this writing have not received a response.
`
`Thank you for your consideration.
`
`Respectfully submitted,
`
`Jill R. Shellow
`
`cc:
`
`AUSAs Ashley Nicholas and Andrew Jones (by ECF and Email)
`Pretrial Officer Francesca Piperato (by email)
`Juan Mercedes (by email)
`Application granted. The conditions of the defendant's pretrial release are modified as follows: the defendant may
`travel to and return from the job interview described in this letter on September 27, 2023. He must travel directly to,
`and return directly from, the location identified here. No deviations are permitted.
`
`The Clerk of Court is directed to terminate the motion pending at Dkt. No. 221.
`
`SO ORDERED.
`
`Dated: September 26, 2023
`New York, New York
`
`MEMORANDUM ENDORSED
`
`USDC SDNY
`DOCUMENT
`ELECTRONICALLY FILED
`DOC #:
`
`
`
`DATE FILED:
`
`
`
`
`
`
`_____________________________________
` GREGORY H. WOODS
` United States District Judge
`
`
`
`
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