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Home Court filings USA v. Ilori et al United States v. Chris Recamier — U.S. District Court, S.D.N.Y. Motion to Appoint Counsel. Document filed by Adedayo Ilori — USA v. Ilori et al. (Dkt. 112, S.D.N.Y.)

Court filing

Motion to Appoint Counsel. Document filed by Adedayo Ilori — USA v. Ilori et al. (Dkt. 112, S.D.N.Y.)

Summary

An ex parte letter motion to appoint associate counsel, Document 112, filed 01/22/23 in United States v. Ilori, 21 Cr. 746 (MKV), in the Southern District of New York, dated January 22, 2023 from Avraham C. Moskowitz to the Honorable Mary Kay Vyskocil. Counsel writes to request the Court's authorization to have an associate counsel assigned, submitted ex parte because it requests permission to expend CJA funds, pursuant to 18 U.S.C. §§ 3006(A) and 3599(f). The letter states that Mr. Ilori is awaiting sentencing following a jury verdict on Counts 1-6 on November 1, 2022, that the sentencing submission is due on January 17, 2023, and that the proposed associate counsel is Christopher A. DeGennaro, Esq., a mentee in the Eastern District's Mentoring Program. It asks the Court to endorse the proposed order.

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Filed January 22, 2023 in USA v. Ilori et al.; one of 179 filings from this case.

Record facts

CourtU.S. District Court for the Southern District of New York
Filed2023-01-22

Cite this document

“Motion to Appoint Counsel. Document filed by Adedayo Ilori — USA v. Ilori et al. (Dkt. 112, S.D.N.Y.).” U.S. District Court for the Southern District of New York, No. 1:21-cr-00746-MKV, Doc. 112, filed 2023-01-22. Archived at Pandemic Darlings, https://pandemicdarlings.com/court-filings/full-docket-adedayo-ilori-nysd-571512/2023-01-22-gov-uscourts-nysd-571512-112-0-doc-112/, SHA-256 49f89be3e15ca7e609fc472576c7552983c1b75831dadda248d12458e5383226.

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Full text

345 Seventh Avenue, 21st Floor 
Avraham C. Moskowitz 
 
New York, NY 10001 
AMoskowitz@mb-llp.com 
 
Phone: (212) 221-7999 
 
 
Fax: (212) 398-8835 
 
 
 
January 22, 2023 
 
BY ECF / EX PARTE 
The Honorable Mary Kay Vyskocil 
United States District Court 
Southern District of New York  
500 Pearl Street 
New York, New York 10007 
Re: United States v. Ilori., 21 Cr. 746 (MKV) 
Your Honor: 
I represent Mr. Adedayo Ilori in the above-referenced matter.  I write to request the Court’s 
authorization to have an associate counsel assigned.  Because this letter requests permission to 
expend CJA funds related to the defense, it is submitted ex parte pursuant to 18 U.S.C. §§ 
3006(A) and 3599(f).  This application is necessary for my effective representation of Mr. Ilori.     
As the Court is aware, Mr. Ilori is awaiting sentencing following a jury verdict, guilty on 
Counts 1-6, on November 1, 2022.  The proposed associate counsel will assist in all aspects of Mr. 
Ilori’s defense in connection with sentencing, including Mr. Ilori’s sentencing submission, which 
is due on January 17, 2023.  Associate Counsel will also assist with Mr. Ilori’s appeal, if we 
continue to represent Mr. Ilori on appeal. The proposed associate counsel is Christopher A. 
DeGennaro, Esq., who is a mentee in the Eastern District’s Mentoring Program.  Mr. DeGennaro 
has many years of trial experience as a state prosecutor and attorney at Foley & Lardner LLP.     
The Board of Judges of the Eastern District of New York has implemented a Mentoring 
Program, which assigns experienced members of the District’s CJA Panel to act as mentors for 
attorneys interested in applying to the Panel.  The program is intended to improve the diversity 
and overall quality of the CJA Panel and is open to all interested and qualified attorneys.  The 
Program is designed to provide those attorneys with federal experience by pairing them with 
mentors and assigning them to cases that the District Court believes are of sufficient complexity to 
warrant the services of multiple attorneys.  The mentee works under the close supervision of the 
mentoring attorney and is subject to the approval of the client and the District Judge to whom the 
case is assigned.  The Mentee provides the first 15 hours on a pro bono basis, and thereafter may 
bill at a rate of $103.00 per hour.  Susan Kellman and Michael Hueston are co-Directors of the 
Eastern District’s Program. 
Case 1:21-cr-00746-MKV     Document 112     Filed 01/22/23     Page 1 of 2

Honorable Mary Kay Vyskocil 
January 22, 2023 
Page 2  
 
 
If this request meets with the Court’s approval, I would appreciate if Your Honor would 
endorse the proposed order, so that I may create an e.voucher and have Mr. DeGennaro begin 
working on the case. 
 
 
Respectfully submitted, 
 
Avraham C. Moskowitz 
 
 
 
 
 
 
 
 
Case 1:21-cr-00746-MKV     Document 112     Filed 01/22/23     Page 2 of 2

File and source

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gov.uscourts.nysd.571512.112.0.pdf
Size
145,185 bytes
SHA-256
49f89be3e15ca7e609fc472576c7552983c1b75831dadda248d12458e5383226
Our copy
gov.uscourts.nysd.571512.112.0.pdf
Original
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  1. Notice of Change of Address as to Adedayo Ilori — USA v. Ilori et al. (Dkt. 114, S.D.N.Y.)same docket · 2023-02-15
  2. Scheduling Order as to Adedayo Ilori — USA v. Ilori et al. (Dkt. 111, S.D.N.Y.)same docket · 2023-01-17
  3. MOTION to Postpone Sentencing . Document filed by Adedayo Ilori — USA v. Ilori et al (Dkt. 110)same docket · 2023-01-17
  4. Motion to Continue. Document filed by Adedayo Ilori — USA v. Ilori et al. (Dkt. 108, S.D.N.Y.)same docket · 2023-01-06
  5. Exhibit A — USA v. Ilori et al (Dkt. 118.1)same docket · 2023-04-24
  6. Exhibit B — USA v. Ilori et al (Dkt. 118.2)same docket · 2023-04-24
  7. Sentencing Submission by USA as to Adedayo Ilori — USA v. Ilori et al. (Dkt. 120, S.D.N.Y.)same docket · 2023-05-01
  8. Exhibit A - Victim Impact Statement Filed under Seal — USA v. Ilori et al. (Dkt. 120-1, S.D.N.Y.)same docket · 2023-05-01
  9. Exhibit B - Judge Liman Sentencing Transcript — USA v. Ilori et al. (Dkt. 120-2, S.D.N.Y.)same case · 2023-05-01
  10. Exhibit C - Proposed Forfeiture Order — USA v. Ilori et al. (Dkt. 120-3, S.D.N.Y.)same case · 2023-05-01
  11. Exhibit D - Proposed Restitution Order — USA v. Ilori et al. (Dkt. 120-4, S.D.N.Y.)same case · 2023-05-01
  12. ENDORSED LETTER as to (21-Cr-746-1) Adedayo Ilori addressed to Judge Mary Kay Vyskocil… — USA v. Ilori et al (Dkt. 123)same case · 2023-05-03
  13. NOTICE OF FILING OF OFFICIAL TRANSCRIPT as to Adedayo Ilori.… — USA v. Ilori et al (Dkt. 128)same case · 2023-06-02
  14. LETTER by Adedayo Ilori addressed to Judge Mary Kay Vyskocil from Sanford Talkin dated… — USA v. Ilori et al (Dkt. 129)same case · 2023-06-09
  15. Sentencing Letter by USA as to Adedayo Ilori addressed — USA v. Ilori et al. (Dkt. 130, S.D.N.Y.)same case · 2023-06-28
  16. Text of Proposed Order of Forfeiture (Ex. A) — USA v. Ilori et al. (Dkt. 130-1, S.D.N.Y.)same case · 2023-06-28
  17. Memo Endorsement as to Adedayo Ilori — USA v. Ilori et al. (Dkt. 89, S.D.N.Y.)same docket · 2022-11-03
  18. Text of Proposed Order of Restitution (Ex. B) — USA v. Ilori et al. (Dkt. 130-2, S.D.N.Y.)same docket · 2023-06-28
  19. Motion for Extension of Time to File. Document filed by Adedayo Ilori — USA v. Ilori et al. (Dkt. 88, S.D.N.Y.)same docket · 2022-11-03
  20. Order as to Adedayo Ilori. On November — USA v. Ilori et al. (Dkt. 87, S.D.N.Y.)same docket · 2022-11-02

Part of: United States v. Chris Recamier — U.S. District Court, S.D.N.Y. · U.S. District Court for the Southern District of New York · Paycheck Protection Program (PPP) · COVID Economic Injury Disaster Loans (EIDL) · Criminal prosecutions · Motions · 2023 · Court filings

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