Letter to Judge Kaplan Re: United States v. Chanette Lewis et al., No. 21 Cr. 729 (Dkt. 78, S.D.N.Y.)
Summary
In this March 13, 2023 letter in United States v. Chanette Lewis et al., No. 21 Cr. 729 (S.D.N.Y.), attorney Ezra Spilke, writing for client Tatiana Daniel, asks U.S. District Judge Lewis A. Kaplan, with the government's consent, for a 50-day adjournment of Daniel's March 29th sentencing hearing. The letter says Daniel's codefendants are believed to be scheduled for sentencing on May 18 at 3:00 PM, fifty days after Daniel's current date, and that Daniel would ask to join them. Counsel says more time is needed to gather records and other mitigation evidence. AUSA Michael Neff has no objection, and the letter calls this Daniel's first request for an adjournment.
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Case1:21-cr-00729-LAK
Case 1:21-cr-00729-LAK Document
Document77
78 Filed
Filed03/13/23
03/14/23 Page
Page11of
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Law Offices of Ezra Spilke
1825 Foster Avenue, Suite 1K
Brooklyn, New York 11230
t: (718) 7 83-3682
e: ezra@spilkelaw.com
www.spilkelaw.com
March 13, 2023
ByECF
The Honorable Lewis A. Kaplan
United States District Court
Southern District of New York
500 Pearl Street
New York, New York 10007
Re: United States v. Chanette Lewis et al., No. 21 Cr. 729
Client: Tatiana Daniel
Dear Judge Kaplan:
With the consent of the government, I write to respectfully request a 50-day
adjournment of Tatiana Daniel's March 29th sentencing hearing. I believe that all
of Ms. Daniel's codefendants are scheduled to be sentenced on May 18 at 3:00 PM,
which is fifty days from Ms. Daniel's current sentencing date. Should the Court
grant this request, Ms. Daniel would ask to join her codefendants on May 18. I am
awaiting records and other mitigation evidence. The additional time will allow me
to complete that effort.
I have conferred with AUSA Michael Neff, who advises me that the
government has no objection to this request. This is Ms. Daniel's first request for an
adjournment. The Court's considerate attention to this matter is greatly
appreciated.
Respectfully submitted,
Ezra Spilke
cc: Tatiana Daniel, by email
AUSA Michael Neff, by ECF
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