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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. 119)

Court filing

LETTER MOTION addressed to Judge Lewis J.… — USA v. Chancy et al (Dkt. 119)

Record facts

CourtU.S. District Court for the Southern District of New York
Filed2022-02-01

U.S. District Court for the Southern District of New York · No. 1:20-cr-00378-LJL · Doc. 119 · 2022-02-01 · Docket on CourtListener

Summary

A letter motion dated February 1, 2022 from counsel for defendant Adedayo Ilori to Judge Lewis J. Liman in United States v. Ilori, No. 1:20-cr-00378-LJL, in the U.S. District Court for the Southern District of New York, filed as Doc. 119. The letter asks the Court to adjourn the sentencing hearing, then scheduled for February 17, until after March 15, 2022. It states that a defense expert's evaluation has not been completed in person because of COVID-19 and Omicron concerns and will proceed virtually. It also cites the need to review additional discovery the Government produced on new charges pending before Judge Vyskocil, and states that the Government takes no position on adjournment. The two-page letter is signed by Brooke Cucinella of Simpson Thacher & Bartlett LLP.

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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 
February 1, 2022 
 
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 February 
17 at 2:00 pm.  Since we last wrote to the Court on December 2, 2021, we have 
retained a psychiatrist to evaluate Mr. Ilori.  Although the expert is in the process of 
evaluating Mr. Ilori, he has not been to conduct an in-person visit with Mr. Ilori in 
light of the recent developments and health concerns relating to the COVID-19 
pandemic and Omicron variant.  While we were hopeful that we would be able to 
schedule an in-person visit for the psychological evaluation, we are proceeding with 
scheduling a virtual evaluation to avoid further delay.   
Additionally, we request this extension in order to review additional 
discovery produced by the Government relating to the new charges against Mr. Ilori1 
pending before Judge Vyskocil, and to discuss these matters with Mr. Ilori’s counsel 
in that matter.  As the Court would expect, the additional time will allow us to 
properly consider and address how, if at all, this evidence impacts the current 
sentencing.  Along those lines, we have represented to the Government that we will 
provide it with at least two weeks’ notice if we believe a Fatico hearing is necessary, 
and we will likewise keep the Court apprised and provide notice as soon as possible.   
                                                 
1 The Government produced over 5 GB of materials.  
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 119     Filed 02/01/22     Page 1 of 2

 
-2- 
February 1, 2022
 
We did not anticipate seeking an additional adjournment but in light of the 
circumstances, we believe that it is necessary for the adequate representation of our 
client.  The Government takes no position on adjournment. 
Therefore, we respectfully request that this Court adjourn Mr. Ilori’s 
sentencing date until after March 15, 2022.   
 
Respectfully submitted, 
Brooke Cucinella 
cc: 
Counsel of record (via ECF) 
/s/ Brooke Cucinella  
Case 1:20-cr-00378-LJL     Document 119     Filed 02/01/22     Page 2 of 2

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