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Letter to Judge D'Agostino, Request for Adjournment of Sentence Date — United States v. Clarke (Dkt. 12)

Summary

Letter dated April 15, 2024, from Paul Hirsch, counsel for Patricia Clarke, to Judge Mae A. D'Agostino in the Northern District of New York, requesting an adjournment of Ms. Clarke's sentence date, currently scheduled for May 7, 2024, and of the sentencing memos due April 16, 2024. It calls this the first such request; Christopher Wright, counsel for co-defendant William Taylor, joins it and the government consents. Hirsch cites the outstanding Presentence Report and pending documents on his clients' background and character, and asks for a date after July 10, 2024, other than 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. Clarke (Dkt. 12).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-no-1-23-cr-00502-dkt-12-dcf4a0b992/, SHA-256 2dc383438a1c9a155b522b324ba4dcd55fc4d06f6cc712f5605b8bac1d288abd.

Full text

          Case 1:23-cr-00502-MAD Document 12 Filed 04/15/24 Page 1 of 1




                                                               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. Patricia Clarke (23-cr-00502-MAD-1)
 Dear Judge D’Agostino:

       I represent Patricia Clarke in the instant indictment and write today to respectfully request
an adjournment of Ms. Clarke’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. Christopher Wright who is counsel for co-defendant, William
Taylor, joins in this request and it is made with the gracious consent of the government.

       I make this request partly because 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/
                                                              Paul Hirsch

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