Letter to Judge McMahon Re: U.S.A. v. Zvi Zigelman, 23-cr-65-CM (Dkt. 36, S.D.N.Y.)
Summary
Gedalia M. Stern of Necheles Law, LLP wrote to Judge Colleen McMahon on April 3, 2023 in U.S.A. v. Zvi Zigelman, 23-cr-65-CM (S.D.N.Y.), asking to extend the time to object to Zigelman's draft PSR from April 14 to April 28. The letter notes that Zigelman recently pleaded guilty to a single-count Information charging PPP and EIDL fraud and that the draft PSR was filed on March 31, making objections due April 14 under Fed. R. Crim. P. 32(f). It explains that Passover, which ran April 5-13 that year and is observed by Zigelman and counsel, made it difficult to meet and review the draft PSR, and reports that the assigned AUSA has no objection.
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Case 1-23-CR-65-CM Document
Case 1:23-cr-00065-CM 34 Filed
Document 36 inFiled
NYSD on U4/U;j/ZUL,j
04/19/23 Page 1 ofl"'ayt:::
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Necheleslaw, LLP
1120 Avenue of the Americas
New Yor~, NY 10036
April 3, 2023
ViaECF
Hon. Colleen McMahon
United States District Court
Southern District of New York
500 Pearl Street
NewYorkN.Y. 10007
Re: US.A. v. Zvi Zigelman, 23-cr-65-CM
Dear Judge McMahon:
We respectfully write to request an extension oftime to object to Mr. Zigelman's draft
PSR, from April 14 to April 28.
As Your Honor is aware, Mr. Zigelman recently pleaded guilty to a single-count
Information charging him with PPP and EIDL fraud. Mr. Zigelman's draft PSR was filed on
March 31 and thus, under Fed. R. Crim. P. 32(f), any objections are due on April 14. Much of the
time between March 31 and April 14, however, is during the holiday of Passover (which this
year runs from April 5-13), which both Mr. Zigelman and undersigned counsel observe and thus
cannot meet to discuss his draft PSR. Moreover, the necessary preparations for Passover have
made it difficult to arrange a time to review the PSR with Mr. Zigelman before the onset of
Passover.
We therefore respectfully request a two-week extension, until April 28, to submit any
objections to Mr. Zigelman's PSR.
I have spoken to the assigned AUSA and she informs me she has no objection to this
request.
Respectfully submitted,
/sf
Gedalia M. Stern
Cc: AUSA Emily Deininger (via ECF)
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