United States v. SPEARMAN

1:20-cr-00631 | S.D.N.Y. | Jul 8, 2022

Case 1:20-cr-00631-AKH Document 299 Filed 07/08/22 Page 1 of 1 Case 1:20-cr-00631-AKH Document 298 Filed 07/07/22 Page 1 of 1 ROTHMAN , SCHNEIDER, SOLOWAY & STERN, LLP

Attorneys at Law 100 Lafayette Street, Suite 501 New York, NY 10013

Franklin A. Rothman Jeremy Schneider Fax: (212) 571-5507 Robert A. Soloway Tel: (212) 571-5500 David Stern

July 7, 2022 By ECF Defendant may submit an order satisfactory to gov’t Hon. Alvin K. Hellerstein and PTS. United States District Court /s/Alvin K. Hellerstein, U.S.D.J Southern District of New York 7/8/2022 500 Pearl Street New York, New York 10007

Re: United States v. Joseph Campbell Ind No.: 20 Cr. 631 (AKH) Dear Judge Hellerstein: I represent Joseph Campbell, who is currently at liberty on bail conditions that include electronic monitoring and home detention with the ability to leave home for approved work. Mr. Campbell currently maintains full time employment, and has been employed almost the entirety of the pendency of the case. He is compliance with his bail conditions. I write seeking a step-down in Mr. Campbell’s electronic monitoring release conditions from home detention to curfew. I have been in contact with Mr. Campbell’s Pre-Trial Services Officer, Jonathon Lettieri, who consents to the proposed modification, as long as the hours of curfew would be at the discretion of Pre-Trial Services. Such step- down is in recognition of the eighteen months of very restrictive home detention status, which is in excess of the level of restriction warranted. The government, by AUSA Ryan Finkel, has no objection to this request, and in all other respects, the parties request that Mr. Campbell’s conditions of release remain as they are.

Thank you for your attention to this matter, and if the Court has any questions about the contents of this letter, it is respectfully requested the parties be notified. Sincerely, Robert A. Soloway Robert A. Soloway

cc: AUSA Ryan Finkel (By ECF) PTSO Jonathon Lettieri (By Email) RAS:sc