LETTER MOTION addressed to Judge Lewis J.… — USA v. Chancy et al (Dkt. 142)

Record facts

U.S. District Court for the Southern District of New York · No. 1:20-cr-00378-LJL · Doc. 142 · 2023-09-19 · Docket on CourtListener

Summary

A government letter motion dated September 19, 2023 to Judge Lewis J. Liman in United States v. Adedayo Ilori, 20 Cr. 378 (LJL), No. 1:20-cr-00378-LJL, in the U.S. District Court for the Southern District of New York, filed as Doc. 142. The letter refers to the court's August 11, 2023 order (ECF No. 134) directing the parties to address whether the court should suspend a drug-testing condition that the order describes as accidentally imposed orally at sentencing and excluded from the written judgment. It states that Sanford Talkin, Esq. was appointed CJA counsel for the defendant on September 6, 2023 under an order of September 1, 2023 (ECF No. 139). Because new counsel is still conferring with the defendant, including about a possible resentencing motion, the government asks to adjourn the September 19, 2023 response deadline to October 6, 2023, with the defense's consent.

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Full text

U.S. Department of Justice 
 
 
 
 
 
 
 
 
United States Attorney 
 
 
 
 
 
 
 
Southern District of New York 
 
The Silvio J. Mollo Building 
One Saint Andrew’s Plaza 
New York, New York 10007 
 
 
 
 
 
 
 
 
 
 
September 19, 2023  
 
 
 
 
BY ECF 
 
The Honorable Lewis J. Liman 
United States District Judge 
Southern District of New York 
500 Pearl Street 
New York, New York 10007 
 
Re: 
United States v. Adedayo Ilori, 20 Cr. 378 (LJL) 
 
Dear Judge Liman: 
 
 
The Government writes in connection with the Court’s order dated August 11, 2023, in 
which the Court ordered the parties to address whether the parties believed the Court should by 
written order or in open court suspend the drug-testing condition that the Court had accidentally 
imposed orally at sentencing and intentionally excluded from the written judgment. (ECF No. 
134). Pursuant to the Court’s order on September 1, 2023, (ECF No. 139), on September 6, 2023, 
Sanford Talkin, Esq. was appointed as CJA counsel in this matter for the defendant Adedayo Ilori. 
Because newly appointed counsel continues to confer with the defendant regarding the Court’s 
August 11th order, and regarding a possible motion for resentencing, the Government respectfully 
requests that the Court adjourn the parties’ September 19, 2023 deadline to respond to the Court’s 
August 11th order to October 6, 2023. The defense consents to the request.  
 
 
Respectfully submitted, 
 
DAMIAN WILLIAMS 
United States Attorney 
 
 
By:  
/s/ 
 
               
 
Cecilia Vogel 
 
 
 
 
 
 
 
Assistant United States Attorney 
 
 
 
 
 
 
 
(212) 637-1084  
Cc: 
Sanford Talkin, Esq. (via ECF) 
 
Case 1:20-cr-00378-LJL     Document 142     Filed 09/19/23     Page 1 of 1

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