-against

LEONID ZALTSBERG,

Defendant.

—————————-—————--——x

Case No iO-CR-437 (SRC)

ffl{DEI

AN APPLiCATION HAVING BEEN MADE TO THIS COURT BY DEFENDANT LEONTI)

ZALTSBERG, for permission for him to extend by 30 days the period ofhis approved travel internationally

in Europe, and Government attorneys Michael C. Vasiliadis, Esq., and AUSA Scott McBride, and United

States Probation Officer Kevin Villa, having no objection to said application and agreeing to the entry ofthe

proposed order,

IT IS HEREBY ORDERED, that delirndani is granted immediate permission to extend the period

of his travel outside of the United States bra 30-day period from August 15, 2012 to September 15, 2012.

IT IS FURTHER ORDERED, that defendant shall provide his Probation Officer with an itinerary

of his extended travel, and said itinerary shall be subject to the approval of the Probation Officer.Dated: August ,2012

Steven R. Kartagener, Esq.

Counsel for Defendant

Michael C. Vasiliadis. sq.

Counsel for the Government
against 

LEONII) ZALTSBIZRG, ORIllR

I)efendant. — x

AN APPLICATION hAVING BEEN VIAI)E TO THIS COURT BY I)EFENI)ANT LFONJI)

ZALTSBERG, for permission for him to extend by 30 days the period ofhis approved travel internationally

in Europe, and Government attorneys Michael C. Vasiliadis. Lsq. and AUSA Scott McBride. and UnitedStates Probation ( )fiicer Kevin Villa, having no objection to said application and agreeing to the entry ol the

proposed order.

IT IS HEREBY ORI)EREI), that defendant is granted immediate permission to extend the period

of his travel outside of the United States For a 30-day period from August 15, 2012 to September 15, 2012.

IT IS FURTHER ORDERED. that dclndan1 shall provide his l’rohal ion Officer with an itinerary

of his extended travel, and said itinerary shall be subject to the approval of the Probation Officer.

Dated: August , 2012

Steven R. Kartagener, Esq. fi

Counsel for Defendant

Michael C. Vasiliadis, Esq.

Counsel for the Government

United States District Judge
BY FAX

August 5. 201 2

Hon. Stanley R. Chesler

t nited Stales [)istrici Judge

Frank R. Laiitenherg 1.5. Post 001cc

& Courthouse. Federal Square

P() Box 999

Newark. N.J 07 1 02

RI.: United States v. Leonid Zaltshcrg

Dear Judge Chesler;

The purpose of this letter is to request respectfully that you approve. wjthout opposition from

any ofthe interested parties, the application of my client, Leonid Zaltsberg, (hereinafter “defendant”) for him to be allowed to continue his international travel in I urope. fhr an additional 30—day period. from August 1 5 201 2 to Scpk mb i I S 2(11 2 \s ‘oii ma’s i ca II in Ma 2012 ‘ on granted defendant permission to travel mternalionally, in Europe, fbr an additional 90—day period, from May 15, 2012 to August 15, 2012, fiIlowing his completion ofan earlier, 60—day period of international travel. At the time, the Court md waied, n conversations that i had with counsel while we were

working out the terms of defendant’s travel. that it would be more inclined to grant such future

periods of international travel if deftmdant made some fruitful efforts to begin paying down his outstanding FI3AR penalty. Defense counsel had informed the (‘ourt that it would he more likely that defendant would be able to raise such furds i Ihe was free to travel in Europe with the Ukrainian

soccer team with which detendani was so eJseR affiliated.

In accordance with our earl er order, de endant traveled m I uropc with hs prolessionai

soccer team from ianuar 9. 2fl1 2. to March 201 2. 1 pun rcturniiW to the Inited States, defendant

1 apologize ftr the last-moment nature ot’ this request. I had worked out the particulars of this application with the Government last keek. and prepared this letter at that time. However, I

inadvertently thi led to submit the letter and the proposed order to the Court because of the fact that

we were extremely busy with other erliptine litigation matters that consumed our lime, and caused

me to overlook the earlier submission of this letter.
the Government as to how he money should be torwarded to the IRS. Subsequently, those funds

were transferred to Internal Revenue Agent Lynn Imbesi,

Although permitted to seek further travel authorization within a week of his return to the

United States in early March, because of the. strain of the previous travel and some other personal

reasons, defendant initially declined to seek such permissIon. and he stayed at home in New Jersey. in frill compliance wilh his current probation, until May 1 5. 201 2. when he commenced the present 90—day period of international travel.

During that 90—day period of international travel, from May 5h to August 1 5”. defendant

has raised an additional $22.000 to be paid to the IRS. which presently sits in my I( )l .A account. and

will soon be transferred to the IRS.

A few weeks ago, dekndant’s grandson. I .eon T3evdcr received an unsolicited inquily from the owner of the soccer team with which defendant is affiliated, asking whether there was any way for defendant to be permitted to remain in Europe for an additional 30 days. It is this gentleman, an extremely wealthy man. and others simi larlv situated, liom whom delèndant hopes to obtain additional monies to he paid to the JR S. in order to work owards paying down his indebtedness.

I have spoken with IRS Attorney Michael C. Vasiliadis. who, in turn, has discussed this

matter with AIJSA Kevin McBride and L iniled States l’robaiion ()flicer Kevin Villa. and at this time

all ofthe relevant parties are not opposed to defcndanfs request fur a final, 30-day extension of his

present travel time in Europe.

For these reasons. we respectfully urge the Cowl to trant delèndant’s request that he be allowed to travel in Europe with his soccer team from August 1 5’ to September 5 of 2012. Thank

you.

Respecihilly submitted.

A:

Steven R kartagener

cc: Michael C Vasiliadis, Esq

AUSA Scott McBride

USPO Kevin Villa