Letter Re: United States of America v. Mariluz Fermin, Bellanilda Fermin and Juan Nolasco, Case No.: 22-CR-00012 (Dkt. 62, S.D.N.Y.)

Summary

Attorney John L. Russo, counsel for defendant Juan Nolasco, writes to Judge J. Paul Oetken on July 26, 2023 in United States of America v. Mariluz Fermin, Bellanilda Fermin and Juan Nolasco, Case No. 22-CR-00012 (JPO). The parties ask for a 45 day adjournment of the sentencing set for August 3, 2023, until September 13th or 14th, to join all defendants and to let Nolasco be sentenced on an older (and unrelated) case before Judge Buchwald on August 3rd. All defense counsel and AUSA Steiner consent, and both sides ask for the exclusion of time under the Speedy Trial Act, if applicable. The endorsement, dated 8/1/2023, reads Granted: sentencing is adjourned to September 19, 2023 at 3:00 pm, with the defendant's submission due by September 5, 2023 and the government's by September 12, 2023.

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Full text

                  Case 1:22-cr-00012-JPO Document 62 Filed 08/01/23 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.



                                                            July 26, 2023


       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 sentencing on August 3, 2023.
               By this letter, the parties respectfully request a 45 day adjournment of sentencing in
       this matter until September 13th or 14th - to join all Defendants. The requested adjournment
       will permit Mr. Nolasco to be sentenced on his older (and unrelated) case before Judge
       Buchwald on August 3rd .
               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, if applicable. Given the
       above, we respectfully request that sentencing in this matter be adjourned for a period of 45 days
       – until September 13th or 14th. The Court’s consideration of this request is greatly appreciated.
       Thank you.

                                                                    Yours truly,

                                                                    John L. Russo
                                                                    John L. Russo (JR6200)
        Case 1:22-cr-00012-JPO Document 62 Filed 08/01/23 Page 2 of 2

JLR: mn
Cc: AUSA Mitzy Steiner(VIA ECF)
    Arthur Trakas, Esq.
    Kevin G. Roe, Esq.
                       Granted.
                       Sentencing is hereby adjourned to September 19,
                       2023, at 3:00 pm. Defendant's sentencing submission
                       is due by September 5, 2023, and the government's
                       sentencing submission is due by September 12, 2023.
                         So ordered.
                         8/1/2023

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