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Home Court filings USA v. Bella — Amos Mundendi filings, U.S. District Court, S.D.N.Y. CONSENT LETTER MOTION addressed to Judge Paul A.… — USA v. BELLA (Dkt. 183)

Court filing

CONSENT LETTER MOTION addressed to Judge Paul A.… — USA v. BELLA (Dkt. 183)

Record facts

CourtU.S. District Court for the Southern District of New York
Filed2022-10-21

U.S. District Court for the Southern District of New York · No. 1:21-cr-00247-PAE · Doc. 183 · 2022-10-21 · Docket on CourtListener

Summary

A consent letter motion dated October 21, 2022 and filed as Document 183 in United States v. Amos Mundendi, 21 Cr. 247 (PAE), in the U.S. District Court for the Southern District of New York, addressed to the Honorable Paul A. Engelmayer. Defense counsel Tamara L. Giwa of Federal Defenders of New York writes with the consent of the government to request a 60-day adjournment of the defendant's sentencing, currently scheduled for November 9, 2022. The letter states that the defendant's circumstances have changed over the past two months and that a mitigation report prepared for sentencing by an expert retained by counsel's office now requires a significant update. It reports that the expert is scheduled to visit the defendant at the MDC on October 24, 2022 and again in the following weeks, and that an adjournment would allow the evaluation to be completed.

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Full text

October 21, 2022 
 
VIA ECF and Email 
 
Honorable Paul A. Engelmayer 
United States District Judge 
Southern District of New York 
40 Foley Square 
New York, NY 10007 
 
Re: 
United States v. Amos Mundendi 
 
21 Cr. 247 (PAE) 
 
Dear Judge Engelmayer, 
 
 
I write with the consent of the government to respectfully request a 60-day 
adjournment of Mr. Mundendi’s sentencing, currently scheduled for November 9, 
2022. As the Court is aware, the state of Mr. Mundendi’s mental health and 
personal circumstances have changed dramatically over the past two months. My 
office had previously retained an expert, Dr. Adeyinka Akinsulure-Smith, to 
conduct an evaluation of Mr. Mundendi and prepare a mitigation report to use at 
sentencing. That report now requires a significant update. Dr. Akinsulure-Smith is 
scheduled to visit Mr. Mundendi at the MDC this coming Monday, October 24, 2022, 
and again in the following weeks. An adjournment would provide Dr. Akinsulure-
Smith sufficient time to complete her evaluation and would allow me to effectively 
prepare for sentencing.  
 
Thank you for your consideration of this request.  
 
 
 
 
 
 
 
 
 
Respectfully submitted, 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
_______________________ 
 
 
 
 
Tamara L. Giwa  
 
 
 
 
Counsel for Amos Mundendi 
 
 
 
 
Federal Defenders of New York 
 
 
 
 
 
 
 
 
(917) 890-9729 
 
 
cc:  
AUSA Dina McLeod (via ECF)  
 
 
Case 1:21-cr-00247-PAE     Document 183     Filed 10/21/22     Page 1 of 1

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