Case 1:16-mj-00229-DJS Document 2 Filed 05/08/16 Page 1 of 9

THE KINDLON LAW FIRM, PLLC

74 CHAPEL STREET

ALBANY, NEW YORK 12207

PHONE (518) 434-1493

FAX (518) 935-9336
WWW. KINDLON.COM
LEE C. KINDLON*
____________________
GENNARO CALABRESE
*ADMITTED IN NEW YORK
AND THE DISTRICT OF COLUMBIA

September 23, 2015

Hon. Daniel J. Stewart
James T. Foley U.S. Courthouse
445 Broadway - 4th Floor
Albany, NY 12207
US v. George Muzio, Jr.
1:16-mj-00229-DJS
Dear Judge Stewart:
This letter is submitted ins support of the defendants request that the court set
release conditions pursuant to 18 USC 3142. Mr. Muzio, who has never been arrested
or detained prior to his arraignment on May 3, 2016. Since then, he has been in the
custody of the US Marshall and housed at Rensselaer County Jail.
It is respectfully requested that, given the defendants character, personal history,
absence of danger to the community, his deep roots in the area and the support
demonstrated by attached documents, the defendant be released subject to conditions.
The defendant is father, husband and son in a tight-knit family.
The defendant was born and raised in Cohoes, New York and is the primary
caretaker for his two boys. Ms. Jennifer Muzio, the defendants spouse, is employed and
is the primary breadwinner. In her letter of support, attached and incorporated as
reference herein, she writes that George is a stay at home dad who drives my children to
school and picks them up every day after school. He takes them to doctors
appointments, dental appointments, goes to the school plays, and juggles coaching three
sports teams that my children play on. Both of my boys enjoy that their dad is the coach
and want him in their lives teaching them baseball. Far from being unemployed, the
defendant may have the most involvedand hardestjob of any adult in his household.
Mr. Muzio is not a danger to the community. Since his arrest, there have been no
allegations of harm to the children in his life, either in his family or those in his orbit.
His sister-in-law, Carolyn McCulloch, writes In all the years I have known him he has
never made me feel like any child, his or my own included, has ever been anything other

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than safe and protected around him.

Mr. Muzio is not a danger to the community. Initially, the attached letters of
support should demonstrate that, in contradiction the presumption built into the law, those
that know the defendant understand that he is a warm, compassionate man with whom
they would trust their own children. There have been no allegations, despite public
requests for such information, that Mr. Muzio has had any contact with any children.
There have been no allegations that the defendant was engaged in the production or
creation of these materials. Finally, Mr. Muzio, out of an abundance of caution and upon
mutual agreement with Cohoes Little League, has resigned from his coaching positions in
order to avoid even the slightest hint of posing a danger to the community.
Should the court find it necessary, Mr. Muzio is prepared, at this time, to live in a
different house than his own family. Pending a full investigation by Child Protective
Services to assure the court of the safety of the Muzio children.
Based upon the enumerated factors in 18 USC 3142, it is respectfully requested
that the court grant the defendants release with conditions to include mental health
treatment, electronic monitoring and home confinement.

Respectfully,
THE KINDLON LAW FIRM, PLLC.
Lee C. Kindlon
lkindlon@kindlon.com

cc: AUSA Emily Farber, US Attorneys Office (via ECF)

enc.

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Your Honor,

I am writing on behalf of my husband, George Muzio jr. We have been married for three years
and weve been together for eighteen. I rely on my husband for a lot of things. He is a stay at
home dad who drives my children to school and picks them up every day after school. He takes
them to doctors appointments, dental appointments, goes to the school plays, and juggles
coaching three sports teams that my children play on. Both of my boys enjoy that their dad is
the coach and want him in their lives teaching them baseball. He is an active member within
the community and people view him this way. He always is there to help out others and he is
always there for me and my children.

We first met in Colonie Center Mall with friends and from one look, I knew he was going to be
my soul-mate. We talked on the phone for hours, went out to eat, went to the movies, and we
love going to concerts. He drove all the way to New York City just to take me to a Dave
Matthews Concert.

Now, our relationship is even stronger. We are active members in the community and with our
children. Both of us support our children with anything they do and most important to become
model citizens with good grades and excellent sportsmanship qualities. We eat dinner together
as much as our sports schedules allow, we go on walks together and go to movies together too.

I know my husband better than he knows himself. He is a kind man with a big heart. He is my
rock and he benefits the community with positive actions and caring demeanor.

Sincerely,

Mrs. Jennifer Muzio Jr

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Julie A. Cone
16 Verdi Boulevard
Latham, New York 12210
518-322-9318
May 5, 2016

To whom it may concern;

My name is Julie Cone and I am George Muzio, Jrs aunt on his fathers side.
I have known George for his entire life, and I have been a big part of his life from his birth.
Georges family and mine have lived in the same house for a good part of his youth, and we
have always been family oriented with George. We have spent many a holiday, birthdays,
vacations and school events together. My children regard George as a brother, as he is an only
child, and to this date share those same feelings.
As an adult I have witnessed George and his 2ife bringing up their two children, who adore their
father. He is a great father to those boys, with baseball, holidays, birthdays, vacations and their
well being. They have a wonderful family values with their parents who they live with, and my
10 siblings and I are there on frequent occasions and can attest to this.
On a more personal level, George has been there for me and my family when we reached out to
him during times of difficulty , as recently as March of this year. My nephew George has always
treated me with utmost respect, and I cherish him dearly.
That being said, I am a Christian woman of faith, and I would extend to you that I have
complete confidence that my nephew George has a lot of family love and support behind him,
and will see to it that he get the help he needs. I believe God will bring George and his family
through this difficult time, and watch over us all.
I thank you for your time and consideration in reading this letter on behalf of my nephew
George Muzio, Jr.
Sincerely,

Julie A. Cone

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To whom it may concern,

This letter is on behalf of George Muzio Jr. I have known George for five years now and he is a wonderful
person. George is always willing to help in any situation. He was there for me when my mother passed
away willing to help in any way. I have been down to the baseball field when George was coaching the
little league team. He is always very supportive with the kids and always saying words of
encouragement.
Sincerely,
Chrissy Cohn

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271 Watervliet-Shaker Rd
Watervliet, NY 12189

May 4, 2016

To whom it may concern,
I am writing on behalf of my son in law, George Muzio Jr whom I have known for 15 years.
George has always been respectful, kind, and a joy to be around. Since he has become a father, he has
always been loving and attentive to his two sons. He helps with their baseball skills and even tried
helping my nephew learn a few things. He was there for us when my mother passed away and when my
other daughters boyfriend was in the hospital. He even raised money to help the family afford to bury
him. My daughter relies on George to be there for her and the boys in the same way and he always is.

Respectfully yours,
Patricia A Gaston

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To whom it may concern,

I am very shocked to be writing to you about the moral character of George Muzio Jr. George
became a part of my family when he started dating my sister, his wife, Jennifer. In all the years I have
known him he has never made me feel like any child, his or my own included, has ever been anything
other than safe and protected around him. He has always been a respectable father. To take him away
from his children would be irresponsible. His boys look up to him and love him deeply. I dont know how
he is accused of this mess but there must be some mistake. I dont believe George is capable of such
things. Please take this under advisement. I would hate to see my nephews, Ryan and Carter, lose their
father.
Thank you for reading my letter.
Sincerely,
Carolyn McCulloch

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George & Cindy Muzio

282 Central Ave.
Cohoes, NY 12047
5/5/2016
Your Honor:
My son has been there for me and his family. When he was a 19 years of age he lost his dog, a
month later his great grandmother and 5 months later his grandmother passed suddenly who he
was very close with. The following month after my mother passed his girl friend (now his wife)
was pregnant. He has dealt with all of that and stood by me in my time of grief and did right by
his wife and children.
George is a devoted husband and father. He has helped raised two fine sons. His children have
good grades and are involved in numerous activities and are very well behaved.
George is my bee keeper, mouse exterminator and my taxi. My husband and myself are afraid of
bees. We always have an overabundance of them. He sprays the hives for us. We live in an old
home and get mice every now and then. He tries to captures them and let them loose outside.
He is more on top of it than my two cats. I do not drive out of my comfort zone. When I need
him he is there to drive me where I need to go. My husband is a smoker trying to quit. George
is his biggest advocate to get him to stop. I know these are trivial things to some people but they
mean a lot to me.
We live in the same house. George and his family on the first floor and my husband and myself
on the second floor. We have one kitchen that we have dinners together. We are a simple
family.
Sincerely,
Mr. and Mrs. George Muzio, Sr.