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Home Court filings USA v. Chancy et al — Adedayo Ilori filings, U.S. District Court, S.D.N.Y. LETTER MOTION addressed to Judge Lewis J.… — USA v. Chancy et al (Dkt. 103)

Court filing

LETTER MOTION addressed to Judge Lewis J.… — USA v. Chancy et al (Dkt. 103)

Record facts

CourtU.S. District Court for the Southern District of New York
Filed2021-11-02

U.S. District Court for the Southern District of New York · No. 1:20-cr-00378-LJL · Doc. 103 · 2021-11-02 · Docket on CourtListener

Summary

A letter motion dated and filed November 2, 2021 as Document 103 in United States v. Ilori, No. 1:20-cr-00378-LJL, in the U.S. District Court for the Southern District of New York, addressed to United States District Judge Lewis J. Liman. Defense counsel Brooke Cucinella of Simpson Thacher & Bartlett LLP writes on behalf of defendant Adedayo Ilori, whose sentencing was scheduled for November 8. With the Government's consent, the letter requests an adjournment of at least 30 days. It states the time is needed to prepare for sentencing, possibly draft a supplemental sentencing letter, coordinate an evaluation related to the September 29, 2021 sentencing memorandum, and review discovery the Government has not yet produced to the defense. The letter is one page.

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Full text

Simpson Thacher & Bartlett LLP 
425 LEXINGTON AVENUE  
NE W YORK , NY 10017-3954 
 
TELEPHONE: +1-212-455-2000  
FACSIMILE: +1-212-455-2502
Direct Dial 
+1-212-455-3070 
 
E-Mail Address
brooke.cucinella@stblaw.com
 
 
BY ECF 
November 2, 2021 
Re: 
United States v. Ilori, No. 20-cr-378 (S.D.N.Y.)  
Dear Judge Liman: 
I represent defendant Adedayo Ilori in the above-captioned action.  As the 
Court is aware, Mr. Ilori’s sentencing is currently scheduled for November 8 at 11 
am.  We have been proactively involved in discussions with the Government relating 
to Mr. Ilori’s most recent arrest, and respectfully request—with the Government’s 
consent—an adjournment of at least 30 days.  This adjournment will provide time 
for us to sufficiently prepare for the sentencing and draft a supplemental sentencing 
letter, if needed.  Among other things, I intend to have a mental health professional 
evaluate Mr. Ilori ahead of the sentencing hearing to provide more context for Mr. 
Ilori’s history and characteristics set forth in our September 29, 2021 sentencing 
memorandum.  An adjournment will allow us to coordinate such an evaluation, 
which presents logistical hurdles because Mr. Ilori is currently incarcerated.  In 
addition, the parties are in ongoing conversations about the Government’s 
production of certain discovery to Mr. Ilori and myself, which I have not yet 
received and will need adequate time to review before the hearing.  We will keep the 
Court updated on our progress. 
Respectfully submitted, 
Brooke Cucinella 
 
cc: 
Counsel of record (via ECF) 
The Honorable Lewis J. Liman 
United States District Judge 
Southern District of New York 
500 Pearl St. 
New York, NY, 10007 
/s/ Brooke Cucinella  
Case 1:20-cr-00378-LJL     Document 103     Filed 11/02/21     Page 1 of 1

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