Letter to Judge McMahon, July 20, 2023, Re: United States v. Moshe Rosenfeld, 23 Cr. 00065 (CM) (Dkt. 50, S.D.N.Y.)
Summary
Defense counsel Sarah Krissoff wrote to U.S. District Judge Colleen McMahon on July 20, 2023 in United States v. Moshe Rosenfeld, 23 Cr. 00065 (CM) (S.D.N.Y.), asking, with the government's consent, for an additional 30-day adjournment of the motions briefing schedule. The letter says materials from phones seized from Rosenfeld and a co-defendant are still outstanding, and that the defense expects its motions to concern in part the search and seizure of cell phones. Under the existing schedule, defense motions were due July 31, the government's opposition August 31, the defense reply September 21 and a conference or hearing was set for October 18. The letter proposes defense motions by August 31, the opposition by September 30 and the reply by October 21, and the defense consents to the exclusion of time under the Speedy Trial Act.
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Case 1:23-cr-00065-CM
Case 1:23-cr-00065-CM Document
Document50
49 Filed
Filed 07/20/23
07/20/23 Page
Page11of
of11
COZEN
Jo'CONNOR
USDCSDNY
July 20, 2023 DOCUMENT Sarah Iuissoff
ELECTRO~ICALLY FILED Direct Phone 212-908-1388
skrissoff@cozen.com
VIA ECF DOC #: 1 , .
DATE FILED: 2 D _1{ /2-3
The Honorable Colleen McMa_
United States District Judge
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Southern District of New York
500 Pearl Street
New York, New York 10007
Re: United States v. Moshe Rosenfeld, 23 Cr. 00065 (CM)
Dear Judge McMahon:
We are writing the Court, with the consent of the Government, through Assistant United
States Attorney Emily Deininger, to respectfully request an additional 30-day adjournment to the
motions briefing schedule previously set by the Court. Under the current schedule, defense
motions are due on July 31, with the Government's opposition due on August 31, the defense
reply due on September 21, and a conference or hearing on this matter to be held on October
18at10a.m.
While the Government has provided voluminous discovery to date, there are materials
outstanding relating to phones seized from Mr. Rosenfeld and his co-defendant. The
Government has advised that it is resolving some technical issues related to the provision of
these materials, and intends to provide them shortly. Accordingly, the defense submits that it
would be most efficient for all to allow time for the Government to produce these materials
before filing its motions - which, we currently anticipate, will relate in part to the search and
seizure of cell phones.
Accordingly, we are respectfully requesting that the defense be allowed until August 31
to file its motions, with the Government's opposition to be submitted on or before September 30,
the defense reply due on or before October 21, and a conference or hearing to be schedule
shortly thereafter at the Court's convenience. AUSA Deininger has no objection to this
adjournment, and the defense consents to the exclusion of time under the Speedy Trial Act until
the date of any rescheduled conference or hearing set by the Court, t~~~ both the production
and review of discovery and the filing of motions. t,_.~\J<;JfA'-.;;,'C-
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