Letter to Judge Engelmayer Requesting Sentencing Adjournment (Mackenzy Toussaint) — USA v. Bella (Dkt. 162, S.D.N.Y.)

Summary

A letter dated June 8, 2022 from Bret E. Martin, counsel for Mackenzy Toussaint, to Judge Paul A. Engelmayer of the U.S. District Court for the Southern District of New York in case 1:21-cr-00247-PAE, filed as Document 162. It asks to adjourn the sentencing then set for August 30, 2022 by 90 days, to some time the week of November 14. It gives counsel's personal reasons and issues the defense has identified in the Pre-Sentence Report, and states that Ms. McLeod has no objection. The court's endorsement of 8/19/2022 grants the motion but finds a 90-day adjournment unjustified, adjourns sentencing until October 19, 2022 at 11:00 a.m., and says the defense should not expect a further adjournment.

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Case 1:21-cr-00247-PAE Document 162 Filed 08/19/22 Page1of1

BRET E. MARTIN
ATTORNEY AND COUNSELOR AT LAW

P.O. BOX 93565
SOUTHLAKHEH, TEXAS 76092

(214)505-2168
BRETMARTINATTY@GMAIL.COM

June 8, 2022

VIA ELECTRONIC FILING AND EMAIL

Honorable Paul A. Engelmayer 91-CR-247-02
Judge of the United States District Court for Cc 7-0
The Southern District of New York

40 Foley Square New York, NY 10007 USA v. Mackenzy Toussaint

Dear Judge Paul A. Engelmayer,

Counsel for Mackenzy Toussaint respectfully submits this letter to request an
adjournment for our scheduled sentencing date that is currently set on August 30, 2022.
Counsel for the Defendant is coming off of a very debilitating 10 day illness and is now
currently in the midst of a surprise 25 year wedding anniversary trip, a child that is
graduating college and starting law school this week and another child that has moved in
the NCAA transfer portal to a new university and starting her new soccer season tonight.
Equally as important, is that Counsel and the Defendant have identified a number of
issues in the Pre-Sentence Report that could significantly impact his sentencing and all of
the arguments surrounding the sentence. We are working on these issues and getting
numerous sets of additional eyes working with our team on this. Counsel has been in
communication with Ms. McLeod concerning all of these issues and she has no objection
to the granting of this adjournment request of 90 days. We would also ask for this to be
scheduled some time the week of November 14, if that is amenable to the Court’s
schedule.

Thank you for your time and attention in this matter.
Truly Yours,
/s/ Bret E. Martin

Bret E. Martin
SBN 00794232

The Court GRANTS the motion to adjourn sentencing, but finds a 90-day adjournment unjustified. Sentencing is
adjourned until October 19, 2022 at 11:00 a.m. The defense should not expect this date to be further adjourned. The
defense’s sentencing submission is due 14 days before the sentencing date. The Clerk of Court is requested to
terminate the motion at Dkt. No. 161. SO ORDERED. 8/19/2022

United States District Judge


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