Letter from Necheles Law, LLP to Judge Colleen McMahon — United States v. Zigelman (Dkt. 41, S.D.N.Y.)

Summary

In this one-page letter filed May 22, 2023 in United States v. Zvi Zigelman, 23-cr-65 (S.D.N.Y.), defense counsel Gedalia Stern asks Judge Colleen McMahon to adjourn Zigelman's sentencing, then scheduled for June 8, by approximately 60 days. The letter says counsel needs more time for third parties to complete parts of the sentencing submission, including a forensic psychiatric report that counsel considers relevant to the Court's exercise of its § 3553(a) discretion. It states that this is the first request to adjourn Zigelman's sentencing and that the assigned prosecutor has no objection. The letter is copied to AUSA Emily Deininger.

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Full text

Case 1:23-cr-00065-CM Document 41 Filed 05/22/23 Page 1 of 1


Necheleslaw, LLP
1120 Avenue of the Americas                                                              Cedalia M. Stern
New YorR, NY 10036                                                                    gms@necheleslaw.com

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Via ECF                                                                      ......
Hon. Colleen McMahon
Daniel Patrick Moynihan
United States Courthouse
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               United States v. Zvi Zigelman, 23-cr-65

Dear Judge McMahon:

       We write to respectfully request an approximately 60-day adjournment of Mr. Zigelman's
sentencing, which is currently scheduled for June 8.

       Counsel for Mr. Zigelman is working on putting together Mr. Zigelman's sentencing
submission and needs additional time for certain parts of it to be completed by third parties-
including a forensic psychiatric report that we think will be relevant to the Court's exercise of its
§ 3553(a) discretion. We therefore respectfully request an approximately two-month
adjournment to allow sufficient time for this work to be completed.

        This is Mr. Zigelman's first request for an adjournment of his sentencing. I have spoken
to the assigned AUSA and she has no objection to this request.


                                              Respectfully submitted,
                                                      Isl
                                               Gedalia Stern

cc: AUSA Emily Deininger (via ECF)




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