On November 21, 2022 a
Letter,Correspondence
was filed
involving a dispute between
Nys Office Of Victim Services,
and
Jamell Modest,
for Special Proceedings - Other (NY Executive Law 632a)
in the District Court of Albany County.
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STATE OF NEW YORK
OFFICE OF THE ATTORNEY GENERAL
LETITIA JAMES DIVISION OF STATE COUNSEL
ATTORNEY GENERAL LITIGATION BUREAU
Writer’s Direct Dial: (518) 776-2593
November 21, 2022
Hon. David Cardona, Chief Clerk
Albany County Supreme Court
Albany County Courthouse, Room 102
16 Eagle Street
Albany, New York 12207
Re: New York State Off. of Victim Services v. Modust
Dear Mr. Cardona:
This office represents the New York State Office of Victims Services (“OVS”) in the
above-captioned Executive Law § 632-a (“Son of Sam”) proceeding. Enclosed for filing with the
Court is a Verified Petition together with supporting Exhibits (redacted as necessary), supporting
Affirmation of Assistant Attorney General Melisa A. Latino, and a No Fee Authorization Letter,
seeking a preliminary injunction to freeze certain funds of the Respondent herein on behalf
of the victim(s) of Respondent’s crimes pursuant to Executive Law § 632-a(3).
If Respondent does not oppose the Petition, this office also encloses a proposed order
granting the preliminary injunction (“PI Order”) for the Court’s use.
Also filed herewith is a proposed Order to Show Cause seeking a temporary restraining
order (“TRO”) to enjoin the aforesaid funds, which upon filing will be presented to the Part
I Justice for review and approval.
Thank you for your time and considerations.
Respectfully yours,
S / Melissa A. Latino
Melissa A. Latino
Assistant Attorney General
Document Filed Date
November 21, 2022
Case Filing Date
November 21, 2022
Category
Special Proceedings - Other (NY Executive Law 632a)
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STATE OF NEW YORK OFFICE OF THE ATTORNEY GENERAL LETITIA JAMES DIVISION OF STATE COUNSEL ATTORNEY GENERAL LITIGATION BUREAU Writer’s Direct Dial: (518) 776-2593 November 21, 2022 Hon. David Cardona, Chief Clerk Albany County Supreme Court Albany County Courthouse, Room 102 16 Eagle Street Albany, New York 12207 Re: New York State Off. of Victim Services v. Modust Dear Mr. Cardona: This office represents the New York State Office of Victims Services (“OVS”) in the above-captioned Executive Law § 632-a (“Son of Sam”) proceeding. Enclosed for filing with the Court is a Verified Petition together with supporting Exhibits (redacted as necessary), supporting Affirmation of Assistant Attorney General Melisa A. Latino, and a No Fee Authorization Letter, seeking a preliminary injunction to freeze certain funds of the Respondent herein on behalf of the victim(s) of Respondent’s crimes pursuant to Executive Law § 632-a(3). If Respondent does not oppose the Petition, this office also encloses a proposed order granting the preliminary injunction (“PI Order”) for the Court’s use. Also filed herewith is a proposed Order to Show Cause seeking a temporary restraining order (“TRO”) to enjoin the aforesaid funds, which upon filing will be presented to the Part I Justice for review and approval. Thank you for your time and considerations. Respectfully yours, S / Melissa A. Latino Melissa A. Latino Assistant Attorney General