Letter — USA v. VALERIO (Dkt. 39)

Record facts

U.S. District Court for the District of New Jersey · No. 3:25-cr-00414-RK · Doc. 39 · 2026-04-07 · Docket on CourtListener

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   JOHN L. RUSSO 
ATTORNEY AT LAW 
 
       COUNSEL 
Milton Florez, Esq. 
Paul Testerverde, Esq. 
J.L. Russo, P.C. 
31 · 19 Newtown Avenue, Suite 500 
Astoria, New York 11102 
Tel:   718 · 777 · 1277 
Fax:   718 · 204 · 2310 
Email:  JLRussoPC@Gmail.com 
         
 
 
 PARALEGAL 
 Maria Nunez, B.S. 
 
 
 
 
 
 
 
 
     
 
 
 
 
 
  April 7, 2026 
 
 
Via E-Mail and ECF  
Honorable Robert A. Kirsch  
United States District Judge 
United States District Court  
District Of New Jersey 
402 East State Street 
Trenton, New Jersey  08608 
 
 
Re: United States v. Damaris Valerio 
      Docket No.: 25 CR 00414 
 
Your Honor: 
 
 
This office represents Damaris Valerio, the defendant in the above referenced 
matter, which is scheduled for sentencing before the Court on April 14, 2026.   We write to 
request a further brief adjournment of sentencing in this matter to a date prior to May 26th 
as the undersigned has been scheduled for a medical procedure on April 14th which has 
proven quite impractical to reschedule. I am available, generally, any days prior to May 
26th,  but not April 14th – 17th, April 22nd – 24th, May 4th -7th and May 11th.  
 
 
The Court will recall, that this matter was adjourned from March 17th, given the 
recent opinion of the District Court (Brann, DCJ) which found the then current 
configuration of the U.S. Attorney’s Office in New Jersey to be unlawful as constituted. 
See,  United States v. Naviwala, Cr. No. 24-00099 [ECF Nos. 317-18], and United States 
v. Torres, Cr. No. 24-378 [ECF Nos. 120-21].    
 
 
While it appears that the U.S. Attorney’s Office has corrected its personnel issues, 
given the foregoing, we respectfully request an adjournment of sentencing a date prior to 
May 26, 2026 as outlined above, and as convenient for the Court.    
Case 3:25-cr-00414-RK     Document 39     Filed 04/07/26     Page 1 of 2 PageID: 140

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The Court’s consideration of this request is respectfully appreciated.  Thank you.   
 
 
 
 
 
 
 
 
Yours truly, 
 
 
 
 
 
 
 
/s/ John Russo   
 
 
 
 
 
 
 
 
 
 
John L. Russo  
  
JLR:mn 
Cc:  AUSA Fatima Cano  
Case 3:25-cr-00414-RK     Document 39     Filed 04/07/26     Page 2 of 2 PageID: 141

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