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Letter, Request That Sentencing Be Scheduled for Late March — United States v. Khaimov (E.D.N.Y., Dkt. 45)

Summary

A letter dated February 10, 2022 to Hon. Joan Azrack in United States v. Khaimov, 20 Crim. 267 (JMA), Document 45, filed 02/10/22, in Case 2:20-cr-00267-JMA-SIL. Isabelle A. Kirshner, attorney for Arkadiy Khaimov, who pleaded guilty on August 12, 2020, asks that sentencing be scheduled for some time in late March after a series of requests to adjourn. The letter says discussions with the government to resolve US v. Khaimov S1 20 Crim. 580 (AMD) have been unproductive, and that Khaimov requested a March sentencing based on his belief that the Hebrew calendar month Adar Bet is auspicious. It says counsel want late March to prepare a comprehensive sentencing submission, and that Bradley King, the assistant assigned to this case, has no objection but is unavailable on March 30, 2022.

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“Letter, Request That Sentencing Be Scheduled for Late March — United States v. Khaimov (E.D.N.Y., Dkt. 45).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-e-d-n-y-no-2-20-cr-00267-dkt-45-e-d-n-y-6066861b27/, SHA-256 987182d3576123b01a3bf6d964f84ad719976f0779cc2dbf9dc74afb8731a5ba.

Full text

Case 2:20-cr-00267-JMA-SIL Document 45 Filed 02/10/22 Page 1 of 1 PageID #: 196


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

                                                                                                 Isabelle A. Kirshner
                                                                                                              Partner
                                                                                               kirshner@clayro.com


                                                     February 10, 2022



Hon. Joan Azrack
United States Courthouse
100 Federal Plaza Central Islip,
New York 11722
BY ECF

                                    Re: United States v. Khaimov
                                        20 Crim. 267 (JMA)

Dear Judge Azrack:

       We are the attorneys for Arkadiy Khaimov, the above named defendant. Mr. Khaimov
pleaded guilty on August 12, 2020. After a series of requests by the defendant to adjourn his
sentence, I am writing to request that sentencing in this matter be scheduled for some time in late
March.

       As you are aware, Mr. Khaimov is a defendant in another matter, US v. Khaimov S1 20
Crim. 580 (AMD). To date, discussions with the government to resolve that matter have been
unproductive and Mr. Khaimov has requested that he be sentenced by your honor in March. Mr.
Khaimov’s request is based on his belief that the corresponding month on the Hebrew calendar,
Adar Bet, is an auspicious month as it is “leap month” which occurs seven times in a nineteen
year cycle. Counsel would request that sentencing take place sometime late in March to afford us
an opportunity to prepare a comprehensive sentencing submission. 1

        Bradley King, the assistant assigned to this case, has no objection to this request but has
indicated that he is unavailable on March 30, 2022.

           Thank you for your continued attention to this matter.


                                    Very truly yours,
                                            /s/
                                    ISABELLE A. KIRSHNER


1
    See https://www.chabad.org/library/article_cdo/aid/70016/jewish/The-Jewish-Leap-Year.htm

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