Letter to Judge Bennett — United States v. Medard Ulysse et al. (D. Md., Dkt. 24, January 24, 2025)

Summary

A Court's Exhibits list for United States v. Medard Ulysse, Case 1:22-cr-00335-RDB, Document 24, filed 01/24/25, in the U.S. District Court for the District of Maryland, with Exhibit No. 1 described as a letter from Richard Bardos and identification and admission dates of 01/24/2025. The letter, dated 23 January 2025 from Richard Bardos, Of Counsel, to Judge Richard D. Bennett, states that sentencing is set for the next day at 11:00 a.m., and alerts the Court to an issue with the potential to cause a rescheduling. It states that sentencing was initially set for December 11, 2024. Bardos states that the meeting with Mr. Ulysse did not take place and that Mr. Ulysse is expected to request a new date.

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

Full text

Text recognized from a scanned document; may contain errors.

Case 1:22-cr-00335-RDB Document 24 _ Filed 01/24/25 Page 1of2
USA

vs.

Medard Ulysse

Civil No. RDB 21-054 & 22-335 Court’s Exhibits
Exhibit No. | Identification Admitted Description
1 01/24/2025 01/24/2025 Letter from Richard Bardos

Exhibit List (Rev. 3/1999)
Case 1:22-cr-00335-RDB Document 24 _ Filed 01/24/25 Page 2 of 2

SCHULMAN, HERSHFIELD & GILDEN, P.A.

ATTORNEYS AT LAW
ONE EAST PRATT STREET
SUITE 904
BALTIMORE, MARYLAND 21202
(410) 332 0850
FAX (410) 332 0866

rbardos@shg-legal.com
23 January 2025
Richard D. Bennett, Judge
United States District Court for
the District of Maryland
101 W. Lombard Street
Baltimore, Maryland 21201
VIA ECF
RE: United States v. Medard Ulysse, et al.
Case Nos. RDB-21-054 and 22-335

Dear Judge Bennett:

Sentencing is set for tomorrow at 11:00 a.m. before Your Honor. I am writing to alert the
Court to an issue that was brought to my attention this morning that has the potential to cause a
rescheduling of this matter.

Mr. Ulysse was initially set for sentencing on December 11, 2024. At that time, the
defendant asked for new counsel and the Court immediately sent Mr. Ulysse and me to Judge
Aslan for an attorney inquiry hearing. Judge Aslan found no grounds for new counsel and we
returned to your courtroom and the Court set January 24, 2025 as the new date, to permit Mr.
Ulysse time to hire counsel if he chose.

Following the inquiry hearing, I told Mr. Ulysse that I would arrange a meeting with him
to address certain issues from that hearing, as well as specific issues to be presented at
sentencing. Unfortunately, due to involvement in a variety of other matters, | forgot about the
meeting and did not meet with the defendant. Mr. Ulysse called me this morning to remind me
of my statement and I realized that he was correct and that I had not done what I had said I
would. | believe that such a meeting is important for proper representation of this defendant.

I do not know whether the Court under these circumstances would reschedule the hearing.
I expect that Mr. Ulysse will request a new date. I wanted to make the Court aware of this issue
as soon as possible.

Thank you for your attention to this matter.

Very truly yours,

Richard Bardos, Of Counsel
RBB:rb


File and source

File

24.pdf

Size

526,282 bytes

SHA-256

3026ed7b7e59cd19848596c7657452ac48b037fd4d029bff8ae09e93462797ce

Our copy

24.pdf

Original

No public link identified.