`
`VIA ECF AND EMAIL
`
`2/12/2024
`
`RE: United States v. Joan Mercedes, 22-cr-522 (GHW)
`
`PLLC
`LAW OFFICES OF JILL R. SHELLOW
`_________________________________________________________________________________________________________
`15 Chester Avenue
`White Plains, NY 10601
`jrs@shellowlaw.com
`212.792.4911 (Telephone)
`203.258.1463 (Mobile)
`February 11, 2024
`The Honorable Gregory H. Woods
`United States District Judge
`Southern District of New York
`500 Pearl Street
`New York, NY 10007
`WoodsNYSDChambers@nysd.uscourts.gov
`Dear Judge Woods:
`I represent Joan Mercedes who is currently on home detention, and according
`to Pretrial Services (PTS) has been compliant with his obligations.
`On February 15, 2024, Mr. Mercedes’ daughter turns 9 years old. Her mother
`is bringing her to New York to celebrate with Mr. Mercedes. Mr. Mercedes would
`like to take his daughter and her mother to Sky Zone (a children’s play space at the
`Ridge Hill mall in Yonkers) followed by dinner at Dave and Busters in the Cross
`County Mall also in Yonkers. We respectfully request a temporary modification of
`Mr. Mercedes’ bail so that he is permitted to leave his home on Thursday,
`February 15, 2024 from 2PM to 9PM for this purpose. I have consulted with AUSA
`Ashley Nicolas and the Government takes no position on this request. PTS’ position,
`as a matter of policy, is to oppose temporary modifications for social reasons.
`Thank you for your consideration. Respectfully submitted,
`Jill R. Shellow
`AUSA Ashley Nicolas (by ECF and email)
`
`cc:
`
`Application denied. The Clerk of Court is directed to terminate the motion pending at Dkt. No. 299.
`
`SO ORDERED.
`
`Dated: February 12, 2024
`New York, New York
`
`
`
`
`_____________________________________
` GREGORY H. WOODS
` United States District Judge
`
`MEMORANDUM ENDORSED
`
`USDC SDNY
`DOCUMENT
`ELECTRONICALLY FILED
`DOC #:
`
`
`
`DATE FILED:
`
`
`
`
`
`

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