MOTION to Postpone Sentencing . Document filed by Adedayo Ilori as to Chris Recamier,… — USA v. Ilori et al (Dkt. 122)

Summary

A letter motion dated May 2, 2023 from defense counsel Avraham C. Moskowitz to Judge Mary Kay Vyskocil in United States v. Adedayo Ilori, 21 Cr. 746 (MKV), in the U.S. District Court for the Southern District of New York, filed as Document 122. It asks for a brief adjournment of the sentencing scheduled for May 8, 2023. The letter gives two reasons: counsel is unavailable on the morning of May 8, and the defendant needs time to review the government's sentencing submission, received May 1. It asks for a date during the weeks of May 15 or May 22 and states that the government has no objection.

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Moskowitz Colson 
Ginsberg & Schulman LLP 
80 Broad Street, Suite 1900 
New York, NY 10004 
(212) 257-6455 
www.mcgsllp.com 
May 2, 2023 
 
VIA ECF  
The Honorable Mary Kay Vyskocil 
United States District Judge 
Southern District of New York 
Daniel Patrick Moynihan United States Courthouse 
500 Pearl Street 
New York, NY 10007 
 
Re:  
United States v. Adedayo Ilori 21 Cr. 746 (MKV) 
Dear Judge Vyskocil: 
 
This letter is respectfully submitted on behalf of the defendant, Adedayo Ilori, to request 
a brief adjournment of the sentencing, currently scheduled to take place before Your Honor on 
May 8, 2023. The adjournment is necessary for two reasons. First, I am unavailable on the 
morning of May 8, because I am needed to accompany my 94 year old father to an important 
doctor’s appointment that was recently scheduled and cannot be postponed. Additionally, I 
received the Government’s sentencing submission on May 1, provided a copy to my client earlier 
today and he informed me that he needs some time to review the submission and consult with me 
about potential responses to the Government’s arguments.  
In light of the above, it is respectfully requested that the Court adjourn Mr. Ilori’s 
sentencing to a date during the weeks of May 15 or May 22 convenient to the Court and the 
parties. In that regard, Ms. Murray advised me that the Government is available any time during 
the week of May 15, with the exception of the afternoon of May 15. I am available any time 
during those two weeks, with the exception of the morning of May 24 and all day on May 26.  
I have discussed the requested extension with AUSA Murray who informed me that the 
Government has no objection to the request.    
 
Thank you in advance for your consideration of this matter.  
Respectfully submitted, 
 
Avraham C. Moskowitz 
Case 1:21-cr-00746-MKV     Document 122     Filed 05/02/23     Page 1 of 2

 
Moskotwitz Colson Ginsberg & Schulman LLP 
2 
 
 
cc: AUSA Juliana Murray (by email) 
      AUSA Daniel Felton (by email) 
 
Case 1:21-cr-00746-MKV     Document 122     Filed 05/02/23     Page 2 of 2

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