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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. 111)

Court filing

LETTER MOTION addressed to Judge Lewis J.… — USA v. Chancy et al (Dkt. 111)

Record facts

CourtU.S. District Court for the Southern District of New York
Filed2021-12-02

U.S. District Court for the Southern District of New York · No. 1:20-cr-00378-LJL · Doc. 111 · 2021-12-02 · Docket on CourtListener

Summary

A letter motion dated December 2, 2021 from Brooke Cucinella of Simpson Thacher & Bartlett LLP, counsel for defendant Adedayo Ilori, to Judge Lewis J. Liman in United States v. Chancy et al, No. 1:20-cr-00378-LJL, in the U.S. District Court for the Southern District of New York, filed as Doc. 111. The letter updates the Court on the defense's retention of an expert to evaluate Mr. Ilori before the sentencing hearing then set for December 9. Because the expert needs until the end of January, it asks the Court to adjourn sentencing until after February 15, 2022, and states that the Government consents. It also reports that the Government produced discovery on November 22, 2021 and that additional discovery arrived that day. The letter is two pages.

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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 
December 2, 2021 
 
Re: 
United States v. Ilori, No. 20-cr-378 (S.D.N.Y.)  
Dear Judge Liman: 
We represent defendant Adedayo Ilori in the above-captioned action.  We 
write to update the Court regarding our retention of a mental health professional to 
evaluate Mr. Ilori ahead of the sentencing hearing currently scheduled for December 
9 at 3:00 pm.  Since we last wrote to the Court on November 15, we have identified 
and spoken to a mental health expert—specifically, a psychiatrist—to evaluate Mr. 
Ilori.  The expert has agreed to provide his services and we are in the process of 
retaining him.  We intend to submit our request for services other than counsel 
soon.  The expert informed us that he will need until the end of January to evaluate 
Mr. Ilori and draft a report.   
In order to ensure that sufficient time is allotted to complete Mr. Ilori’s 
assessment, we respectfully request that this Court adjourn Mr. Ilori’s sentencing 
date until after February 15, 2022.  We recognize that this is a significant 
adjournment. However, we believe that it is necessary to ensure adequate 
representation of our client in light of the amount of time the expert stated he 
needed to conduct Mr. Ilori’s evaluation. The Government has consented to this 
adjournment. 
In addition, the Court previously asked for an update on discovery.  The 
Government produced discovery on November 22, 2021 and we received additional 
discovery today, which we have not yet reviewed.  We are waiting for production of 
any post-arrest statements made by any alleged co-conspirators that could implicate 
Mr. Ilori.  We will keep the Court updated on our progress.   
 
The Honorable Lewis J. Liman 
United States District Judge 
Southern District of New York 
500 Pearl St. 
New York, NY, 10007 
Case 1:20-cr-00378-LJL     Document 111     Filed 12/02/21     Page 1 of 2

 
-2- 
December 2, 2021
 
 
Respectfully submitted, 
Brooke Cucinella 
cc: 
Counsel of record (via ECF) 
/s/ Brooke Cucinella  
Case 1:20-cr-00378-LJL     Document 111     Filed 12/02/21     Page 2 of 2

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