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Letter, Count Cooks Sentencing — United States v. Lewis et al. (S.D.N.Y., Dkt. 93, October 1, 2021)

Summary

Letter dated September 29, 2021 to Judge Loretta A. Preska from Darren LaVerne of Kramer Levin, Case 1:20-cr-00234, Document 93, filed 10/01/21 (S.D.N.Y.), in United States v. Lewis et al. The firm represents Count Cooks, whose sentencing is presently scheduled for October 15, 2021, with the sentencing memorandum due on October 1, 2021. The letter states that a forensic psychologist is evaluating Mr. Cooks and the evaluation has been delayed by Covid-related restrictions at MDC and other scheduling issues. It asks that sentencing be adjourned to November 30, 2021, with the memorandum due two weeks prior, calls this the second request for an adjournment, and states that the government has no objection. It carries the signature /s/ Darren A. LaVerne.

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“Letter, Count Cooks Sentencing — United States v. Lewis et al. (S.D.N.Y., Dkt. 93, October 1, 2021).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-no-1-20-cr-00234-dkt-93-s-d-n-y-6b314981a8/, SHA-256 2d16889b812e404cff85865e12509b93c491bf52b2580c25f25fb9c6438400a3.

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Case 1:20-cr-00234-LAP Document 93 Filed 10/01/21 Page 1 of 1
Case 1:20-cr-00234-LAP Document 92 Filed 09/29/21 Page 1 of 1

m 1 Darren LaVerne 1177 Avenue of the Americas
Kra er Levin Partner New York, NY 10036

T 212.715.9190 F 212.715.9100

F 212.715.8190 F 212.715.8000

dlaverne@kramerlevin.com

September 29, 2021
The Honorable Loretta A. Preska NT
United States District Court | IC ee
Southern District of New York 7 oe
500 Pearl Street - EO - | ae
New York, NY 10007 7” GED. |O “lakes

Re: United States v. Lewis et al., No. 20-CR-00234 (LAP)

Dear Judge Preska:

We represent Count Cooks in the above-captioned action. Sentencing is presently
scheduled for October 15, 2021, and, pursuant to the Court’s rules, our sentencing memorandum
is due two weeks prior, on October 1, 2021. In connection with our submission, we are having
Mr. Cooks evaluated by a forensic psychologist. Due to Covid-related restrictions at MDC and
other scheduling issues, the psychologist has been delayed in completing her evaluation.

Accordingly, we ask that the sentencing date be adjourned to November 30, 2021, At (, / LOM
with our memorandum due two weeks prior.

This is our second request for an adjournment. We have conferred with the
government, which has no objection to this request.

80 TREE » Ly Respectfully submitted,

LORETTA A TT /s/ Darren A. LaVerne
OHITED STATES DISTRICT pinay Darren A. LaVerne

Leah S. Friedman

4 FO oY Harry P. Morgenthau

CC: AUSA Adam S. Hobson (by ECF)

KRAMER LEVIN NAFTALIS & FRANKEL LLP KL3 3356584.1

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