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Letter, Request for Another and Final Adjournment of the Sentencing Proceeding (E.D.N.Y., Dkt. 43)

Summary

A letter dated December 2, 2021 to Hon. Joan Azrack in United States v. Khaimov, 20 Crim. 267, Document 43, filed 12/02/21, in Case 2:20-cr-00267-JMA-SIL. Isabelle A. Kirshner, attorney for Arkadiy Khaimov, who pleaded guilty on August 12, 2020 and is scheduled to be sentenced on February 9, 2022, requests another and final adjournment until sometime in March of 2022. The letter says Khaimov is a defendant in another matter, US v. Khaimov S1 20 Crim. 580 (AMD), with a status conference scheduled for January 19, 2022. It says counsel will be prepared to proceed to sentencing in this case regardless of the outcome of discussions with the government, and that Bradley King, the assistant assigned to this case, has no objection.

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“Letter, Request for Another and Final Adjournment of the Sentencing Proceeding (E.D.N.Y., Dkt. 43).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-e-d-n-y-no-2-20-cr-00267-dkt-43-e-d-n-y-dbeebe566a/, SHA-256 ada33245db084067e747d852de28ab64bfedbaf4229a3548f8367d850cee2e95.

Full text

Case 2:20-cr-00267-JMA-SIL Document 43 Filed 12/02/21 Page 1 of 1 PageID #: 194


                                                                                       305 Madison Avenue
                                                                                       New York, NY 10165
                                                                                           T: 212-922-1080
                                                                                           F: 212-949-8255

                                                                                         Isabelle A. Kirshner
                                                                                                      Partner
                                                                                       kirshner@clayro.com


                                              December 2, 2021

Hon. Joan Azrack
United States Courthouse
100 Federal Plaza Central Islip,
New York 11722
BY ECF                        Re: United States v. Khaimov
                                  20 Crim. 267 (JYA)

Dear Judge Azrack:

We are the attorneys for Arkadiy Khaimov, the above named defendant. Mr. Khaimov pleaded
guilty on August 12, 2020. He is currently scheduled to be sentenced by your honor February 9,
2022. I am writing to request another and final adjournment of the sentencing proceeding. As I
am sure your honor is aware, Mr. Khaimov is a defendant in another matter, US v. Khaimov S1
20 Crim. 580 (AMD). We are in discussions with the government in an attempt to resolve that
matter and would like additional time to address the issues that are presented by having to deal
with two sentencing proceedings. A status conference in that case is scheduled for January 19,
2022 and I remain hopeful that an agreement can be reached that will allow for a disposition in
that matter.

We are, therefore, requesting an adjournment of the sentencing proceeding until sometime in
March of 2022. While I am hopeful that we will have resolved these issues by that time, we will
be prepared to proceed to sentencing on this case regardless of the outcome of our discussions.

Bradley King, the assistant assigned to this case, has no objection to this request.

Thank you for your continued attention to this matter.


                               Very truly yours,
                                       /s/
                               ISABELLE A. KIRSHNER

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