Letter to Judge McMahon, May 8, 2024, Re: United States v. Moshe Rosenfeld, 23 Cr. 65 (CM) (Dkt. 87, S.D.N.Y.)
Summary
In this May 8, 2024 letter to U.S. District Judge Colleen McMahon, defense counsel Sarah Krissoff of Cozen O'Connor asks to adjourn the sentencing of Moshe Rosenfeld, set for May 29, 2024 in 23 Cr. 65 (CM), by approximately 45 days. The letter says the defense has not sought an adjournment before. It gives three reasons: the defense is still trying to obtain medical records from Israel, it needs more time to review the long draft Presentence Report with Rosenfeld through a Hebrew translator, and it is still gathering documents the Probation Office requested. The letter says the government, through Assistant U.S. Attorney Emily Deininger, has no objection.
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Full text
Case 1:23-cr-00065-CM
Case 1:23-cr-00065-CM Document
Document 87
86 Filed
Filed 05/09/24
05/08/24 Page
Page 11of
of22
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Via ECF
The Honorable Colleen McMahon
United States District Judge
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Southern District of New York
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500 Pearl Street
New York, New York 10007
Re: United States v. Moshe Rosenfeld, 23 Cr. 65 (CM)
Dear Judge McMahon:
We are writing in connection with the sentencing for Mr. Rosenfeld, which is currently
scheduled for May 29, 2024. After consulting with both the Government and the Probation
Office, we are respectfully requesting a short adjournment of the sentencing for approximately
45 days . We have not previously sought to adjourn Mr. Rosenfeld's sentencing.
The adjournment is needed for a few reasons . First, we are attempting to obtain relevant
medical records from Israel, and have not yet been able to obtain those records (and, in tum,
provide them to the Probation Department). Second, while we are in the process of reviewing
the first draft of the Presentence Report with Mr. Rosenfeld, due to the length of the report and
the need to utilize the services of a Hebrew translator in connection with that review, we need
additional time to thoroughly review the Presentence Report and provide any objections to
Probation. In addition, we are continuing to track down additional documentation requested by
Probation. The Government, through Assistant United States Attorney, Emily Deininger, has
informed us that they have no objection to this request.
Thank you for your consideration of this matter.
Respectfully submitted,
US DC SONY
DOCUMENT
ELECtRO~lCALLY FILED
DOC#:---- - ~ = Sarah Krissoff
DATE FILED: -~ fq /2..Lf
3 'NTC 175 Greenwich Street 55th Floor New York, NY 10007
212.509.9400 800 .437.7040 212.509.9492 Fax cozen.com
Case
Case 1:23-cr-00065-CM
1:23-cr-00065-CM Document
Document 86
87 Filed
Filed 05/08/24
05/09/24 Page
Page 2 of 2
The Honorable Colleen McMahon
Via ECF
Page 2
cc : Emily Deininger and Jennifer Ong, Assistant United States Attorneys (Via EC and E-
Mail)
Ashley Geiser, United States Probation Officer (Via E-Mail)
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