Court filing

Letter from Andrew John Dalack to Judge Valerie E. Caproni, September 26, 2022 — United States v. Frazier (Dkt. 38, S.D.N.Y.)

Summary

Assistant Federal Defender Andrew John Dalack asked Judge Valerie E. Caproni on September 26, 2022 for a 90-day extension of Marcus Frazier's September 30, 2022 surrender date in United States v. Marcus Frazier, 21 Cr. 649 (VEC) (S.D.N.Y.). The letter says Frazier is scheduled for surgery on September 28, 2022, and attaches as Exhibit B a doctor's letter confirming the date, which defense counsel also confirmed by phone with the surgical coordinator on September 22, 2022. The defense argues that the time needed for knee surgery and recovery through physical therapy warrants the extension. Dalack writes that AUSA Katherine Reilly was consulted and that the government does not object.

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Filed September 26, 2022 in Marcus Frazier; one of 7 filings from this case.

Record facts

Court	U.S. District Court for the Southern District of New York
Filed	2022-09-26

Cite this document

“Letter from Andrew John Dalack to Judge Valerie E. Caproni, September 26, 2022 — United States v. Frazier (Dkt. 38, S.D.N.Y.).” U.S. District Court for the Southern District of New York, No. 1:21-cr-00649, Doc. 38, filed 2022-09-26. Archived at Pandemic Darlings, https://pandemicdarlings.com/court-filings/us-v-marcus-frazier/2022-09-26-letter-from-andrew-john-dalack-to-judge-valerie-e-caproni-se-dkt-38/, SHA-256 091b811d11264497629612efd4ec4b4d4f3ae90572c16fe1b39a6c42d32cb0b2.

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Full text

Case 1:21-cr-00649-VEC Document 38 Filed 09/26/22 Page 1 of 1




                                              September 26, 2022

By E-mail & 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:

      I write to respectfully request a 90-day extension of Marcus Frazier’s
September 30, 2022, surrender date. The Government does not object to this
application.

       Mr. Frazier is scheduled to undergo             surgery on September 28,
2022, to repair                                 . See Exhibit A             .
Dr. Andrew             of                          requested the MRI on Mr.
Frazier’s behalf and will perform the surgery. See Exhibit B (letter from Dr.
Andrew             confirming date of surgery). On September 22, 2022, upon
receiving the letter attached as Exhibit B, I also spoke with Carmen
          , Dr.          ’s Surgical Coordinator, by phone to confirm Mr.
Frazier’s appointment.

       The defense respectfully submits that the time needed for Mr. Frazier
to obtain knee surgery and adequately recover through physical therapy
warrants a 90-day extension of his surrender date. I have conferred with
AUSA Katherine Reilly and the Government does not object to this
application.
                                              Respectfully Submitted,


                                              Andrew John Dalack, Esq.
                                              Assistant Federal Defender
Cc:    AUSA Katherine Reilly

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