Consent Letter Motion — United States v. Gomez (Dkt. 38, S.D.N.Y.)

Summary

Thomas H. Nooter, attorney for Vanessa Gomez, asked Judge Edgardo Ramos on January 3, 2022 to move the change-of-plea hearing in United States v. Vanessa Gomez, 21 Cr. 245 (ER) (S.D.N.Y.), set for 11:00am on January 6, 2022, to later in the day, preferably after 2:30pm. The consent letter motion says Nooter has a dermatological procedure scheduled that morning and may not reach court in time for an 11am appearance. AUSA Danielle Kudla has no objection provided the time is 2:30pm or later, the letter says. A so-ordered endorsement dated 1/3/2022 sets the change of plea hearing for January 6, 2022 at 2:30 p.m.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Record facts

Full text

Case 1:21-cr-00245-ER Document 38 Filed 01/03/22 Page 1 of 1




                  1/3/2022   FREEMAN, NOOTER & GINSBERG
                                      ATTORNEYS AT LAW

LOUIS M. FREEMAN                                                               75 MAIDEN LANE
THOMAS H. NOOTER*                                                                 SUITE 503
LEE A. GINSBERG                                                             NEW YORK, N.Y. 10038

                                                                                (212) 608-0808
*NY AND CALIF. BARS                                                        TELECOPIER (212) 962-9696


                                     January 3, 2022
                                     The change of plea hearing will be held on January 6, 2022
Honorable Edgardo Ramos              at 2:30 p.m.
United States District Judge         SO ORDERED.
Southern District of New York
40 Foley Square
New York, NY 10007                                                    1/3/2022
                                                                   Consent Letter Motion

RE:       United States v. Vanessa Gomez, 21 Cr. 245 (ER)

Your Honor:

      I am writing to respectfully request that the change-of-plea hearing now
scheduled for 11:00am on January 6, 2022 be moved to a time later in the day,
preferably after 2:30pm.

      The reason for this request is that I am scheduled to have a dermatological
procedure on the morning of the 6th, and I am not sure I can make it to Court on
time for an 11am appearance.

       I have communicated with AUSA Danielle Kudla, the prosecutor in this
matter, and she has no objection to this request provided the time is 2:30pm or
later.

          Thank you so much for Your Honor’s consideration of this application.

                                                 Sincerely,

                                                 /s/ Thomas H. Nooter
                                                 Thomas H. Nooter
                                                 Attorney for Defendant Gomez

cc:       AUSA Danielle Kudla, by ECF

File and source

File

38.pdf

Size

172,101 bytes

SHA-256

5e3d14515c6da1ad55b889b5b4b73d7a8370f6278adb83212000903e9cb576fa

Our copy

38.pdf