Letter Re: United States of America v. Mariluz Fermin, Bellanilda Fermin and Juan Nolasco, Case No.: 22-CR-00012 (Dkt. 21, S.D.N.Y.)

Summary

A letter dated March 15, 2022 from John L. Russo, counsel for defendant Juan Nolasco, to Judge J. Paul Oetken in United States of America v. Mariluz Fermin, Bellanilda Fermin and Juan Nolasco, Case No. 22-CR-00012 (JPO), filed as Document 21. The parties ask for a 30-45 day adjournment of the initial conference set for March 16, 2022, to review extensive discovery and discuss resolution of the indictment before trial; all defense counsel and AUSA Steiner consent, and both sides request exclusion of time under the Speedy Trial Act. The Court's endorsement, so ordered 3/16/2022, grants the request, adjourns the conference to May 2, 2022 at 12:30 pm and excludes time through May 2, 2022, finding that the ends of justice outweigh the interests of the public and the defendant in a speedy trial.

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                  Case 1:22-cr-00012-JPO Document 21 Filed 03/16/22 Page 1 of 2

                                            J.L. Russo, P.C.
 JOHN L. RUSSO                       31 · 19 Newtown Avenue, Suite 500                        PARALEGAL
ATTORNEY AT LAW                            Astoria, New York 11102                         Maria Nunez, B.S.
                                             Tel: 718 · 777 · 1277
  COUNSEL                                    Fax: 718 · 204 · 2310
Milton Florez, Esq.                    Email: JLRussoPC@Gmail.com
Michael Horn, Esq.




                                                              March 15, 2022


       Via ECF
       Honorable. J. Paul Oetken
       United States District Court Judge
       Thurgood Marshall
       United States Courthouse
       40 Foley Square
       New York, NY 10007

               Re: United States of America v. Mariluz Fermin , Bellanilda Fermin and Juan Nolasco ,
                   Case No.: 22-CR-00012 (JPO)

       Your Honor:

               This office represents, the Defendant Juan Nolasco in the above-referenced matter
       which is scheduled for an initial conference at 2:30 p.m. March 16, 2022
               By this letter, the parties respectfully request a 30-45 day adjournment of the initial
       conference in this matter. The Government has made available extensive discovery which is
       still being reviewed with the Defendants. The requested adjournment will permit the parties to
       evaluate the evidence and discuss resolution of the indictment prior to trial.
               This request is consented to by all defense counsel and AUSA Steiner. Both sides consent
       to, and request, the exclusion of time pursuant to the Speedy Trial Act. Given the above, we
       respectfully request that that he initial conference in this matter be adjourned for a period of 30-
       45 days. The Court’s consideration of this request is greatly appreciated. Thank you.
   Granted.
   The March 16, 2022 pretrial conference is adjourned to May        Yours truly,
   2, 2022, at 12:30 pm. The Court hereby excludes time
   through May 2, 2022, under the Speedy Trial Act, 18 USC           John L. Russo
   3161(h)(7)(A), finding that the ends of justice outweigh the      John L. Russo (JR6200)
   interests of the public and the defendant in a speedy trial.
   So ordered: 3/16/2022

       JLR: mn
        Case 1:22-cr-00012-JPO Document 21 Filed 03/16/22 Page 2 of 2

Cc: AUSA Mitzy Steiner(VIA ECF)
    Arthur Trakas, Esq.
    Kevin G. Roe, Esq.

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