Court filing

Letter from Andrew John Dalack to Judge Valerie E. Caproni, September 26, 2022 — United States v. Frazier (Dkt. 39, S.D.N.Y.)

Summary

Marcus Frazier's lawyer, Assistant Federal Defender Andrew John Dalack, wrote to Judge Valerie E. Caproni on September 26, 2022 seeking a 90-day extension of Frazier's September 30, 2022 surrender date in United States v. Marcus Frazier, 21 Cr. 649 (VEC) (S.D.N.Y.); the letter was filed as Document 39. It says Frazier is scheduled to undergo surgery on September 28, 2022, and that the doctor who requested the MRI will perform it, with a confirming letter attached as Exhibit B. The defense submits that the time needed to obtain surgery and recover through physical therapy warrants the extension. The government, through AUSA Katherine Reilly, does not object, the letter says.

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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. 39, S.D.N.Y.).” U.S. District Court for the Southern District of New York, No. 1:21-cr-00649, Doc. 39, 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-39/, SHA-256 e3b9d73ff5537a924de0238e5ad778e77c4dc849d108af7102fd88f0b9fef2bd.

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Full text

Case 1:21-cr-00649-VEC Document 39 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      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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Size: 212,475 bytes
SHA-256: e3b9d73ff5537a924de0238e5ad778e77c4dc849d108af7102fd88f0b9fef2bd
Our copy: 39.pdf