`
`11/15/2023
`
`Case 1:22-cr-00522-GHW Document 253 Filed 11/15/23 Page 1 of 2
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`RE: United States v. Santos (Joan Mercedes), 22-cr-522 (GHW)
`
`LAW OFFICES OF JILL R. SHELLOW PLLC
`_________________________________________________________________________________________________________
`15 Chester Avenue
`White Plains, NY 10601
`jrs@shellowlaw.com
`212.792.4911 (Telephone)
`203.258.1463 (Mobile)
`November 5, 2023
`The Honorable Gregory H. Woods
`United States District Judge
`Southern District of New York
`500 Pearl Street
`New York, NY 10007
`Dear Judge Woods:
`I represent Joan Mercedes, and I am writing to respectfully request that Your
`Honor modify his bail conditions from home incarceration to a curfew (still with
`location monitoring) where PTS would determine the curfew hours.
`Last week, PTS updated me on Mr. Mercedes. PTS said that he has been
`reporting weekly, testing negative for marijuana, and that there have not been any
`problems with his location monitoring. PTS is encouraging Mr. Mercedes to enroll
`in STRIVE, a training program that prepares people for jobs that require OSHA
`certifications such as flagging. The next STRIVE program starts this week. I also
`understand that Mr. Mercedes has a job interview this week to help deliver food and
`beverages. This modification is necessary for Mr. Mercedes to participate in STIVE
`or to accept the job offer. The AUSAs’ position is that they defer to PTS.
`Thank you for your consideration. Respectfully submitted,
`Jill R. Shellow
`AUSA Andrew Jones (by ECF and email)
`cc:
`AUSA Ashley Nicholas (by ECF and email)
`Pretrial Officer Francesca Piperato (by email)
`Joan Mercedes (by email)
`Admitted: NY, CT, DC
`
`USDC SDNY
`DOCUMENT
`ELECTRONICALLY FILED
`DOC #:
`
`
`
`DATE FILED:
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`
`
`MEMORANDUM ENDORSED
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`
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`Case 1:22-cr-00522-GHW Document 253 Filed 11/15/23 Page 2 of 2
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`Application denied without prejudice to renewal. This letter states that pretrial services supports
`Mr. Mercedes's enrollment in the STRIVE program. The letter does not expressly state that
`pretrial services supports the proposed modification at this time, however. The letter states that
`the next STRIVE program was to begin the week of the request, but does not state that Mr.
`Mercedes was enrolled in the program. The Court requests further clarification regarding the
`position of pretrial services regarding the requested modification of the defendant's conditions of
`pretrial release as well as further information regarding the timing for the defendant's participation
`in the STRIVE program and the defendant's ability to participate in the program under his current
`conditions of pretrial release.
`
`November 15, 2023
`
`SO ORDERED.
`Dated:
`New York, New York
`
`
`
`
`_____________________________________
` GREGORY H. WOODS
` United States District Judge
`
`
`
`
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