Letter from Andrew J. Dalack to Judge Valerie E. Caproni, July 5, 2022 — United States v. Frazier (Dkt. 29, S.D.N.Y.)

Summary

Assistant Federal Defender Andrew J. Dalack asks U.S. District Judge Valerie E. Caproni, in a July 5, 2022 letter written with the Government's consent, for a two-day extension, to July 7, 2022, for the defense sentencing submission in United States v. Marcus Frazier, 21 Cr. 649 (VEC). The letter says the defense is not seeking an adjournment of the July 18, 2022 sentencing proceeding. Dalack writes that the time is needed to "perfect" Frazier's submission and to confer further with the defense's retained mitigation/psychological expert about the expert's report on Frazier, which bears on the Court's consideration of the 18 U.S.C. § 3553(a) factors.

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Case 1:21-cr-00649-VEC Document 29 Filed 07/05/22 Page 1 of 1




                                             July 5, 2022

BY ECF
Honorable Valerie E. Caproni
United States District Court
Southern District of New York
40 Foley Square
New York, New York 10007

Re:    United States v. Marcus Frazier,
       21 Cr. 649 (VEC)

Dear Judge Caproni:

       With the Government’s consent, I write to respectfully request a two-
day extension, to July 7, 2022, for the defense to file its sentencing
submission in connection with the above-captioned case. I am not seeking an
adjournment of the July 18, 2022, sentencing proceeding. I require a two-day
extension of the July 5, 2022, deadline to perfect Mr. Frazier’s sentencing
submission and to further confer with the defense’s retained
mitigation/psychological expert about the report she prepared concerning Mr.
Frazier, which bears on the Court’s consideration of the 18 U.S.C. § 3553(a)
factors.

       Thank you for considering this application.

                                             Respectfully Submitted,



                                             Andrew J. Dalack, Esq.
                                             Assistant Federal Defender
Cc:    AUSA Katherine C. Reilly
       Counsel for the Government            Counsel for Marcus Frazier

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