Letter to Judge McMahon Re: United States v. Zvi Zigelman, 23-cr-65 (Dkt. 65, S.D.N.Y.)
Summary
In this letter filed October 3, 2023 in United States v. Zvi Zigelman, 23-cr-65 (S.D.N.Y.), defense attorney Susan Necheles asks Judge Colleen McMahon to adjourn Zigelman's sentencing. Necheles writes that the sentencing submission was due the following day and that COVID had kept counsel from finishing it. The government agreed to a week-long adjournment but had a conflicting trial, so the defense, also citing counsel's Thanksgiving travel plans, requests a December date convenient to the court; the government consents. A copy went to AUSA Emily Deininger.
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Full text
Case 1:23-cr-00065-CM Document b4 1-11ea .LU/U,j/L.:5 t-'ctye .1 u1 .1
Case 1:23-cr-00065-CM Document 65 Filed 10/03/23 Page 1 of 1
NechelesLaw, LLP
1120 Avenue of the Americas Susan R. Necheles
New Yori:?, NY 10036 srn@necheleslaw.com
212-997-7400
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Hon. Colleen McMahon 10('.$(4-7
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United States District Court
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500 Pearl Street
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Re: United States v. Zvi Zigelman, 23-cr-65
Dear Judge McMahon:
I write to respectfully an adjournment of Mr. Zigelman' s sentencing.
Mr. Zigelman's sentencing submission is currently due tomorrow. Unfortunately,
however, I came down with COVID over the weekend and have not been able to work this week
on finalizing the defense submission. I therefore asked the government if they would consent to a
week-long adjournment so I could finalize the submission once I felt better.
The government graciously consented to this request, but noted that the week
adjournment would create a conflict with an upcoming trial they had. In order t~avoid a conflict
with that trial, as well as defense counsel's Thanksgiving travel plans, we respectfully request an
adjournment of Mr. Zigelman's sentencing until a date convenient to Your Hoq._or in December.
We have spoken to the government and they consent to this request.
Respectfully,
Isl
Susan Necheles
Cc: AUSA Emily Deininger (via ECF)
USDC SDNY
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