Case 2:20-cr-00267-JMA-SIL Document 37 Filed 02/11/21 Page 1 of 1 PageID #: 185
305 Madison Avenue
Clayman & LLP
New York, NY 10165
T: 212-922-1080
Rosenberg
F: 212-949-8255
Isabelle A. Kirshner
Partner
kirshner@clayro.com
February 11, 2021
Hon. Sandra Feuerstein
United States Courthouse
100 Federal Plaza
Central Islip, NY 11722
BY ECF
Re: United States v. Khaimov
20 Crim 267 (267)
Dear Judge Feuerstein:
We are the attorneys for Arkadiy Khaimov, the above-named defendant. Mr. Khaimov
pleaded guilty on August 12, 2020 and is scheduled to be sentenced on March 10, 2021. I am
writing to request an adjournment of the sentencing proceeding.
As I am sure your honor is aware, Mr. Khaimov was arrested on December 21, 2020 and
is now charged in an indictment, US v. Khaimov, 20 Crim. 580 (AMD), which is pending before
Judge Donnelly. He is currently detained at the M.D.C.
The new matter has been designated as a complex matter and we anticipate voluminous
discovery, none of which has been provided. Obviously, the new indictment presents
complicated sentencing issues that need to be addressed. We do not know what Mr. Khaimov’s
exposure is on the new matter or the impact on the plea before your honor.
We are, therefore, requesting time to try to resolve the new case and evaluate its impact
on the matter before you. Therefore, we are respectfully respecting that sentencing in the above
entitled matter be adjourned until sometime in July 2021. Bradley King, the assigned AUSA has
no objection to this request.
Thank you for your attention to this matter.
Very truly yours,
/s/
ISABELLE A. KIRSHNER
cc: Bradley King, Esq.