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USA v. Rose

Docket 1:19-cr-00789, New York Southern District Court (Nov. 6, 2019)
Judge Paul G. Gardephe, presiding
DivisionFoley Square
FlagsCLOSED, APPEAL, ECF
Deadline(Signed by Judge Paul G. Gardephe on 2/7/2027) (lnl)
DeadlineI write to request that the Court grant a temporary modification of Barrington Reid's bond conditions so that he may attend two conventions: the first from February 25th-27th, 2022
Defendant Anthony Rose
Defendant Jelani Wray
Defendant Nathaniel Coles
...
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No. 959 MEMO ENDORSEMENT as to Anthony Rose (1) granting 958 LETTER MOTION addressed to Judge Paul ...

Document USA v. Rose, 1:19-cr-00789, No. 959 (S.D.N.Y. Aug. 3, 2023)
Honorable Paul G. Gardephe United States District Judge Southern District of New York 40 Foley Square New York, NY 10007 Re: United States v. Anthony Rose, 19 Cr.
789 (PGG) Dear Judge Gardephe: I write with the consent of Pretrial Services and without objection from the Government to respectfully request that the Court modify Anthony Rose’s travel restrictions to allow his attendance at four business-related trainings and conferences over the next several months.
Since his release in this case, Mr. Rose has traveled numerous times in connection with his work.
Mr. Rose now requests the Court’s permission to travel on the following dates: • 8/25/2023 – 8/27/2023: Key West, FL • 9/22/2023 – 9/24/2023: Myrtle Beach, SC • 10/20/2023 – 10/22/2023: Fayetteville, NC • 11/17/2023 – 11/19/2023: Orlando, FL Thank you for your consideration of this request.
Attorneys Dated: August 3, 2023
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No. 894 ORDER as to Tara Rose

Document USA v. Rose, 1:19-cr-00789, No. 894 (S.D.N.Y. Jun. 24, 2022)
The Pre-Sentence Report (“PSR”) states that in October 2019, Rose “was diagnosed with [a] Subarachnoid Hemorrhage (SAH), a type of stroke that is mostly caused by a brain aneurysm, and she underwent emergency surgery.” (PSR (Dkt. No. 877) § 170; see Def.
(Dkt. No. 887) at 2) In connection with sentencing, defense counsel has submitted a report from a neurologist addressing the Defendant’s medical condition as of December 2020.
(See id., Ex. C (Jacobs Report dated Dec. 18, 2020) (Dkt. No. 887-3)) Counsel argues that the Defendant’s medical condition requires a non-incarceratory sentence.
(Id. at 1) In order to determine whether a non-incarceratory sentence is appropriate in light of the Defendant’s medical condition, the Court requires information as to what her medical condition is now; not what her medical condition was in October 2019 or in December 2020.
The records submitted should be from her treating physicians, including any specialists personally involved in her ongoing medicalcare.
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No. 868 MEMO ENDORSEMENT as to Latifah Abdul-Khaliq (23) granting 865 LETTER MOTION addressed to Judge ...

Document USA v. Rose, 1:19-cr-00789, No. 868 (S.D.N.Y. May. 23, 2022)
c o m May 20, 2022 Honorable Paul G. Gardephe United States District Judge Southern District of New York 40 Foley Square New York, NY 10007 Dated: May 23, 2022 Re: United States v. Latifah Abdul-Khaliq, Docket No. 19 Cr.
789 (PGG) Dear Judge Gardephe: The purpose of this letter motion is to request a modification of defendant Latifah Abdul-Khaliq’s conditions of pretrial release, to permit her to travel from her present residence, located at 5400 Montbrook Circle, Apt.
A, Richmond, Virginia, to Durham, North Carolina, so that she may visit with her son, Mustafa Abdul-Khaliq, one last time prior to her scheduled BOP surrender date of June 10, 2022.
If this application is granted, Latifah Abdul-Khaliq would travel by car and stay at the home of her friend, Anthony Beiser, which is located at 2234 Holly Hill Drive, Durham, North Carolina.
Louis Pellegrino Tessier-Miller have been informed of counsel’s intention to file this application, and neither has any objection.
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No. 857 MEMO ENDORSEMENT as to Tonya Thomas (12) on 854 SECOND LETTER MOTION addressed to Judge Paul ...

Document USA v. Rose, 1:19-cr-00789, No. 857 (S.D.N.Y. May. 6, 2022)
Honorable Paul G. Gardephe United States District Judge Southern District of New York Thurgood Marshal Courthouse 40 Foley Square New York, NY 10007
RE: United States v. Tonya Thomas (Rose, et al), 19 Cr.
789 (PGG) Your Honor: I am writing again to request a final two-week postponement of the sentencing hearing date (now scheduled for May 18, 2022), with the parties’ sentencing submissions to be rescheduled accordingly (defense two weeks prior to the hearing, and government one week prior).
The reason for the request is that I have been very overwhelmed with work on other cases, and through a misunderstanding by my client, I have not completed the task of obtaining documents I need for my sentencing submission (which is due today).
I have consulted with AUSA Louis Pellegrino and he has no objection to this request.
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No. 842 JUDGMENT In A Criminal Case (S4 19-Cr-789-2)

Document USA v. Rose, 1:19-cr-00789, No. 842 (S.D.N.Y. Apr. 18, 2022)
Motion for Judgment
__ It is ordered that the defendant must notify the United States attorney forthis district within 30 days of any change ofname,residence, or mailing addressuntilall fines, restitution,costs, and special assessments imposedby this judgmentarefully paid.
If orderedto pay restitution, the defendant must notify the court and United States attorney of material changes in economic circumstances.
as directed by the probation officer, the Bureau of Prisons, or any state sex offender registration agency in the location where you reside, work, are a student, or were convicted of a qualifying offense.
You must not own, possess, or have accessto a firearm, ammunition, destructive device, or dangerous weapon(i.e., anything that was designed, or was modified for, the specific purpose of causing bodily injury or death to another person such as nunchakusortasers).
** Justice for Victims of Trafficking Act of 2015, Pub. L. No. 114-22. ; *** Findings for the total amount of losses are required under Chapters 109A, 110, 110A, and 113A of Title 18 for offenses committed on or after September 13, 1994, but before April 23, 1996.
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No. 826 MEMO ENDORSEMENT 822 CONSENT LETTER MOTION addressed to Judge Paul G. Gardephe from Thomas ...

Document USA v. Rose, 1:19-cr-00789, No. 826 (S.D.N.Y. Apr. 8, 2022)
Honorable Paul G. Gardephe United States District Judge Southern District of New York Thurgood Marshal Courthouse 40 Foley Square New York, NY 10007
RE: United States v. Tonya Thomas (Rose, et al), 19 Cr.
789 (PGG) Your Honor: I am writing to request a three-week postponement of the sentencing hearing date (now scheduled for April 21, 2022), with the parties’ sentencing submissions to be rescheduled accordingly (defense two weeks prior to the hearing, and government one week prior).
The reason for the request is that until recently I have been involved in a multi-week jury trial and because I only received the “final” PSR today.
I have consulted with AUSA Mathew Andrews and he has no objection to this request.
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No. 828 CONSENT PRELIMINARY ORDER OF FORFEITURE/MONEY JUDGMENT as to Dejahnea Brown

Document USA v. Rose, 1:19-cr-00789, No. 828 (S.D.N.Y. Apr. 8, 2022)
789 (PGG)(the “Indictment”), with conspiracy to violate the Travel Act, in violation of Title 18, United States Code, Section 371 (Count One); WHEREAS, the Indictment included, inter alia, a forfeiture allegation as to Count One of the Indictment, seeking forfeiture to the United States, pursuant to Title 18, United States Code, Section 981(a)(1)(C), and Title 28, United States Code, Section 2461(c) of any and all property, including but not limited to a sum of money in United States currency representing the amount of proceeds traceable to the commission of the offense charged in Count Oneof the Indictment that the Defendant personally obtained; WHEREAS, on or about July 16, 2021, the Defendant pled guilty to Count One of the Indictment, pursuant to a plea agreement with the Government, wherein the Defendant admitted the forfeiture allegation with respect to Count Oneofthe Indictment and agreedto forfeit to the United States, pursuant to Title 18, United States Code, Section 981(a)(1)(C), and Title 28, United States Code, Section 2461(c), a sum of money equal to no less than $48,000 in United States currency, representing the amount of proceeds traceable to the commission ofthe offense charged in Count Oneofthe Indictment that the Defendant personally obtained; WHEREAS, the Defendant consents to the entry of a money judgment in the amount of $48,000 in United States currency representing the amount of proceedstraceable to the offense charged in Count One of the Indictment that the Defendant personally obtained; and WHEREAS, the Defendant admits that, as a result of acts and/or omissions of the Defendant, the proceeds traceable to, the offense charged in Count Oneof the Indictment that the Defendant personally obtained cannot be located upon the exercise of due diligence.
Pursuant to Rule 32.2(b)(4) of the Federal Rules of Criminal Procedure,this Consent Preliminary Order of Forfeiture/Money Judgment is final as to the Defendant, DEJAHNEA BROWN,and shall be deemed part of the sentence of the Defendant, and shall be included in the judgment of conviction therewith.
All payments on the outstanding money judgment shall be made bypostal moneyorder, bank orcertified check, made payable,in this instance, to the United States Marshals Service, and delivered by mail to the United States Attorney’s Office, Southern District of New York, Attn: Money Laundering and Transnational Criminal Enterprises Unit, One St. Andrew’s Plaza, New York, New York 10007 andshall indicate the Defendant’s name and case number.
Pursuant to Rule 32.2(b)(3) of the Federal Rules of Criminal Procedure, the United States Attorney’s Office is authorized to conduct any discovery neededto identify, locate or dispose of forfeitable property, including depositions, interrogatories, requests for production of documents and the issuance of subpoenas.
The signature page of this Consent Preliminary Order of Forfeiture/Money _ Judgment may be executed in one or more counterparts, each of which will be deemedan original butall of which together will constitute one and the same instrument.
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