# Document EFTA 02845945



# The Law Offices of MONTELL FIGGINS,LLC
17 Academy Street, Suite 305

Newark, New Jersey 07102

Phone: (973) 242-4700

Fax: (973) 242-4701

vAwaigginslave.com BRANCH

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140 East Ridgewood Avenue

Paramus. NJ 07640

Reply to Newark Office [X]

Of Counsel

Douglas Mitchell. Esq.

Linda Childs. Esq.

March 10, 2021

# SENT VIA ECF
Honorable Anal isa U.S. Southern District of NY 500 Pearl Street New York, NY 10007

30 Wall Street 8- Floor

New York. NY 1005

Re: USA v Michael et al. Docket No.: 1:19-er-00830 Request for Emergency Out of State Travel

Your Honor,

This firm represents Defendant, Michael in the above-captioned matter. We are seeking the courts permission for Michael to take an emergency trip to the State of Georgia to tend to his sick father.

Kristen McKeown, his pre-trial services officer, does not oppose his emergency travel.

Respectfully yours

/s/ Montell Figgins

Montell Figgins, Esq.

Attorney for Defendant Michael

cc: Nicolas Roos, Esq., Counsel for Plaintiff Rebekah Donaleski, Esq., Counsel for Plaintiff Jessica Lonergan, Esq., Counsel for Plaintiff Jason Erroy Foy, Esq, Counsel for Defendant Noel