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Letter to Judge D'Agostino, Request for Adjournment of Sentence Date — United States v. Taylor (Dkt. 10)

Summary

Letter dated April 15, 2024, from defense counsel Christopher Wright to Judge Mae A. D'Agostino of the Northern District of New York, asking to adjourn the sentence date of William Taylor, currently scheduled for May 7, 2024, and the sentencing memos due April 16, 2024. The letter says this is the first adjournment request, that Paul Hirsch, counsel for co-defendant Patricia Clarke, joins it, and that the government consents. The stated reasons are that financial documents were only recently furnished to the government and that the Presentence Report is still outstanding. Counsel asks for a date after July 10, 2024, except the week of July 23, 2024 through July 30, 2024.

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“Letter to Judge D'Agostino, Request for Adjournment of Sentence Date — United States v. Taylor (Dkt. 10).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-no-1-23-cr-00501-dkt-10-48a1827dfc/, SHA-256 6f495579d3ec18ebad822e293b911365b080223d75aa34c509152c9d6cf9cb5c.

Full text

          Case 1:23-cr-00501-MAD Document 10 Filed 04/15/24 Page 1 of 1




                                   WL| Wright Law
                                        ATTORNEY AT LAW

                             299 BROADWAY, SUITE 708
                                NEW YORK, NY 10007
                   OFFICE (212) 822-1419 • FACSIMILE (212) 822-1463
                             wrightlawnyc@gmail.com
                                         www.wrightlaw.nyc


                                                               April 15, 2024


VIA ECF
The Honorable Judge Mae A. D'Agostino
United States District Judge
Northern District of New York
James T. Foley Courthouse
445 Broadway
Albany, NY 12207

                Re:     United States v. William Taylor (23-cr-00501-MAD-1)
 Dear Judge D’Agostino:

         I represent William Taylor in the instant indictment and write today to respectfully request
an adjournment of Mr. Taylor’s sentence date which is currently scheduled for May 7, 2024, and
a concomitant adjournment of the sentencing memos due April 16, 2024. This is our first request
for a sentence adjournment. Paul Hirsch who is counsel for co-defendant, Patricia Clarke, joins
in this request and it is made with the gracious consent of the government.

        I make this request in that we have only recently furnished the government with important
financial documents which will prove necessary in the drafting of our respective sentencing
memos. In addition, the U.S. Department of Probation Presentence Report (“PSR”) is still
outstanding and of course the PSR will be a vital document in our sentencing applications. The
defense is also awaiting other documents regarding our clients’ background and character. This
additional time will allow the parties to properly prepare and draft our sentencing memos.

         We therefore, respectfully request a sentence date after July 10, 2024, that works best for
the Court, except for the week of July 23, 2024 through July 30, 2024. I have advised counsel
for the government, AUSA Jonathan Reiner, regarding the instant application and the government
consents.

                                                              Sincerely,
                                                              /s/
                                                              Christopher Wright

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