JOINT LETTER by USA as to Adedayo Ilori, Chris Recamier addressed to Judge Mary Kay… — USA v. Ilori et al (Dkt. 16)

Summary

A joint status letter from the Government on behalf of the parties, dated January 31, 2022, Document 16, stamped Filed 01/31/22, to Judge Mary Kay Vyskocil in United States v. Adedayo Ilori & Chris Recamier, 21 Cr. 746 (MKV), in the Southern District of New York. The Government reports that it produced discovery on January 7, 2022 and January 24, 2022, including search warrants and affidavits, Recamier's post-arrest interview, subpoena responses and electronic device content, and that its Rule 16 obligations are substantially complete. It lists outstanding materials, including discovery from Ilori's prior case, United States v. Ilori, 20 Cr. 378 (LJL). It asks for a conference in about forty-five days and an exclusion of time under the Speedy Trial Act.

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[Type text] 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
January 31, 2022 
 
BY ECF 
 
The Honorable Mary Kay Vyskocil   
 
 
 
United States District Judge  
 
 
 
 
 
 
Southern District of New York 
 
 
 
 
 
 
500 Pearl Street 
 
 
 
 
 
 
 
 
 
 
New York, New York 10007  
 
 
 
 
 
 
 
 
 
Re: 
United States v. Adedayo Ilori & Chris Recamier,  
21 Cr. 746 (MKV) 
 
Dear Judge Vyskocil: 
 
The Government respectfully writes on behalf of the parties to provide the Court with a 
status update.   
 
The Government produced discovery to the defendants on January 7, 2022 and January 24, 
2022.  These productions have included, among other things, copies of executed search warrants 
and search warrant affidavits, defendant Chris Recamier’s post-arrest interview, subpoena 
responses from at least approximately 47 entities, law enforcement reports, and content from 
approximately eighteen electronic devices recovered from the defendants incident to search and 
their arrests.  Through these productions, the Government’s Rule 16 obligations are substantially 
complete.  The outstanding matters yet to be produced are (1) images of approximately three 
devices recovered incident to the defendants’ arrests that have not yet, or only partially, been 
accessed, which will be produced on a rolling basis when (and if) access to these devices is 
established; (2) additional items identified pursuant to search warrant reviews of seized devices, 
which will be produced on a rolling basis as items are identified; (3) additional anticipated 
subpoena returns, which will be produced on a rolling basis as they are received; and (4) the 
discovery productions made in the course of defendant Adedayo Ilori’s prior criminal case, United 
States v. Ilori, 20 Cr. 378 (LJL), which will be produced within the next approximate week. 
 
The parties respectfully request that the Court set a conference in approximately forty-five 
days, at which time the parties hope to be in a position to set a motion schedule or trial date.  To 
the extent that COVID-19 related restrictions make it difficult for counsel to adequately meet with 
their incarcerated clients and determine what motions to be made, the parties will write to the Court 
with any requested adjournment in advance of the scheduled conference. 
 
The Government further moves, with the consent of defense counsel, for the exclusion of 
time under the Speedy Trial Act through the next scheduled conference.  Such an exclusion would 
 
The Silvio J. Mollo Building 
 
 
 
 
 
 
 
 
 
 
 
 
 
One Saint Andrew’s Plaza 
 
 
 
 
 
 
 
 
 
 
 
 
 
New York, New York 10007 
U.S. Department of Justice 
United States Attorney 
Southern District of New York 
Case 1:21-cr-00746-MKV     Document 16     Filed 01/31/22     Page 1 of 2

 
 
 
 
 
be in the interests of justice, as it would allow the defendants time to review discovery and 
contemplate motions, and it would also allow the parties time to discuss the possibility of pretrial 
dispositions.  See 18 U.S.C. § 3161(h)(7)(A). 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Respectfully submitted, 
 
DAMIAN WILLIAMS 
United States Attorney for the 
 
Southern District of New York 
 
 
 
 
 
 
 
 
 
 
 
 
 
      By: /s/__________________________ 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Daniel G. Nessim 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Assistant United States Attorney 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
(212) 637-2486 
cc:  all counsel of record (by ECF) 
Case 1:21-cr-00746-MKV     Document 16     Filed 01/31/22     Page 2 of 2

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