Home/Source documents/First Motion in Limine Emergent Motion for an Order — United States v. Adrienne Ponzo (Dkt. 132, D.N.J.)
First Motion in Limine Emergent Motion for an Order — United States v. Adrienne Ponzo (Dkt. 132, D.N.J.)
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Case 1:24-cr-00267-KMW Document 132 Filed 07/01/26 Page 1 of 2 PageID: 753
UNITED STATES DISTRICT COURT
DISTRICT OF NEW JERSEY
UNITED STATES OF AMERICA :
:
v. : CRIM.NO.24-cr-267 (KMW)
:
ADRIENNE PONZO :
EMERGENT NOTICE OF MOTION FOR AN ORDER EXTENDING DEFENDANT’S
VOLUNTARY SELF-SURRENDER DATE OR, IN THE ALTERNATIVE, RECOMMENDING
DESIGNATION TO A BUREAU OF PRISONS FEDERAL MEDICAL CENTER
ORAL ARGUMENT IS NOT REQUESTED
TO: Honorable Karen M. Williams, U.S.D.J.
PLEASE TAKE NOTICE that Defendant Adrienne T. Ponzo, by and through her attorney, Troy
A. Archie, Esq., respectfully moves this Court on an emergent basis for an Order extending Defendant’s
voluntary self-surrender date. In the alternative, Defendant respectfully requests that this Court
recommend that the Bureau of Prisons immediately designate Ms. Ponzo to an appropriate Federal
Medical Center or other medically appropriate Bureau of Prisons facility capable of treating her
significant respiratory and spinal conditions and, to the extent practicable, designate her to a facility
closer to her residence to permit meaningful family visitation during her custodial sentence.
This Motion is supported by the attached Certification of Counsel, the accompanying
Memorandum of Law, the attached medical records and physician opinions, and all prior proceedings
before this Court.
Counsel respectfully advises the Court that this Motion is being filed immediately after learning of
significant new medical developments while counsel is temporarily away on a previously scheduled
family vacation. Due to limited internet connectivity while traveling internationally, counsel has been
unable to communicate with the Government before filing this emergent application. Counsel files this
Motion out of an abundance of caution so that the Court may consider these newly developed
circumstances as soon as possible. Upon restoration of reliable internet service, counsel will immediately
provide the Government with a copy of this Motion and advise the Court of the Government’s position if
one is received.
Case 1:24-cr-00267-KMW Document 132 Filed 07/01/26 Page 2 of 2 PageID: 754
Oral argument is respectfully not requested.
Respectfully submitted,
/s/ Troy A. Archie, Esq.
Attorney for Defendant