Letter from Necheles Law, LLP to Judge Colleen McMahon — United States v. Zigelman (Dkt. 43, S.D.N.Y.)

Summary

In this letter filed May 24, 2023 as Document 43 in United States v. Zvi Zigelman, 23-cr-65 (S.D.N.Y.), Gedalia M. Stern of Necheles Law, LLP asks U.S. District Judge Colleen McMahon for a brief adjournment of Mr. Zigelman's sentencing, which the Court had moved from June 8 to July 26 after an earlier defense request (Dkt. # 39 and Dkt. # 41). The letter gives two reasons: July 26 falls during the Nine Days of the Jewish calendar, which end with the Fast of Tisha B'av, and counsel has a planned vacation abroad from June 29 to July 16 while the defense submission is due July 12. It asks for a sentencing date after August 7 and says the assigned AUSA has no objection.

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 1:23-cr-00065-CM oocumem 4L i--11~u uo1L,::>1L0 .--- a.~'"' ... v, ...
          Case 1:23-cr-00065-CM Document 43 Filed 05/24/23 Page 1 of 1
Necheleslaw, LLP
1120 Avenue of the Americas                                                    Gedalia M. Stern
New YorR, NY 10036                                                          gms@necheleslaw.com
                                                                                     212-997-7400




ViaECF
Hon. Colleen McMahon
Daniel Patrick Moynihan
United States Courthouse
5 00 Pearl St.
New York, NY 10007-1312

               United States v. Zvi Zigelman, 23-cr-65

Dear Judge McMahon:

       We write to respectfully request a brief adjournment of Mr. Zigelman's recently re-
scheduled sentencing.
       As Your Honor is aware, last week we applied for an approximately 60-day adjournment
of Mr. Zigelman's June 8 sentencing. See Dkt. # 39. The Court then rescheduled Mr. Zigelman's
sentencing for July 26. Dkt. # 41.
        Unfortunately, the new date of July 26 presents two problems for Mr. Zigelman and
counsel, respectively. First, July 26 is during the Nine Days, the most inauspicious time in the
Jewish calendar when the Talmud instructs that people should avoid court. See
https:llen.wikipedia.orglwikilThe_Nine_Days#:~:text=The%20Nine%20Days%20of%20Av, %2
2Ninth%20of%20Av%22). The Nine Days conclude with the Fast of Tisha B 'Av, when
observant Jews commemorate the destruction of the ancient Temples in Jerusalem. This year,
Tisha B'av begins on the evening of July 26 and concludes on the 27 th .
       Second, under Your Honor's Individual Rules, the defense submission in this case is now
due on July 12. My wife and I, however, have a planned vacation abroad from June 29 to July
16.
        For these reasons, we respectfully request an adjournment of Mr. Zigelman's sentencing
until a date convenient to Your Honor after August 7, so that counsel has a week to finalize the
sentencing submission after he returns from his vacation.
        I apologize to the Court for not including these details in my prior adjournment letter and
requiring a second motion to the Court.
       I have spoken to the assigned AUSA and she has no objection to this request.

                                              Respectfully submitted,
                                                     Isl
                                              Gedalia Stem              I,-===================::::;-
                                                                           USDC. SDN)'
cc: AUSA Emily Deininger (via ECF)
                                                                          DOCUMENT
                                                                          ELECTRONICALLY FILED
                                                                          DOC#:
                                                                          DATE F-IL-E-D:_5_Z.._,.i_--,(L_I'---~-

File and source

File

gov.uscourts.nysd.593470.43.0.pdf

Size

41,648 bytes

SHA-256

ba87205e766d335935a47c5a52f9165129793a542962328e02ed4094cdd75fb0

Our copy

gov.uscourts.nysd.593470.43.0.pdf

Original

archive.org