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Letter to Judge Ramos Re: United States v. Elvin German, 21 Cr. 245 (ER) (Dkt. 46, S.D.N.Y.)

Summary

Defense counsel Mark I. Cohen wrote this March 29, 2022 letter to U.S. District Judge Edgardo Ramos in United States v. Elvin German, 21 Cr. 245 (ER), filed March 30, 2022 as Document 46 in the Southern District of New York. Writing for both parties, counsel requests the defense's second adjournment of sentencing, from April 13, 2022 at 3:30 p.m. to the week of April 25, 2022, with matching changes to the sentencing submission deadlines. Two reasons are given: the defense still awaits records about Mr. German's minor child and employment record, and A.U.S.A. Danielle Kudla is unavailable April 11 through April 18, 2022. The Court's endorsement, marked SO ORDERED, adjourns sentencing to April 29, 2022 at 11 a.m. and extends the submission deadlines accordingly.

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Full text

           Case 1:21-cr-00245-ER Document 46 Filed 03/30/22 Page 1 of 1

The Honorable Edgardo Ramos
January 21, 2021
Page 1 of 1




                                                                       March 29, 2022

VIA ECF
The Honorable Edgardo Ramos
United States District Judge
Southern District of New York
                                                                                          3/30/2022
500 Pearl Street
New York, New York 10007

                               Re: United States v. Elvin German
                                   21 Cr. 245 (ER)

Dear Judge Ramos:

        Please recall that I represent Mr. Elvin German in the above-referenced matter. Mr.
German is presently scheduled for sentencing before Your Honor on April 13, 2022 at 3:30 p.m.,
and per Your Honor’s Individual Rules, the defense’s sentencing submission is due Wednesday,
March 30, 2022. For the reasons that follow, the defense writes on behalf of the parties to jointly
request that Your Honor grant a two-week adjournment of the sentencing hearing and adjust the
parties’ respective sentencing submission deadlines accordingly. This is the defense’s second
sentencing hearing adjournment request in this matter.

       The defense is substantially finished preparing its sentencing letter; however, we are still
lacking some proof that Mr. German has been diligently working to obtain, including important
records concerning his minor child, as well as materials related to his employment record. We
have been assured that we will receive these important materials by the end of this week. In
addition, A.U.S.A. Kudla has advised that she will be out of the country during the scheduled
sentencing date, and she would like to personally appear on this matter.

        Therefore, I respectfully request a two-week adjournment of Mr. German’s sentencing
hearing until the week of April 25, 2022, as A.U.S.A. Kudla has advised that she is unavailable
April 11 through April 18, 2022. Further, I respectfully request that the due dates for the parties’
respective sentencing submissions be adjusted to correspond with Mr. German’s new anticipated
sentencing date and in accordance with Your Honor’s Rules. Thank you for your consideration.

                                                                       Respectfully submitted,


                                                                       Mark I. Cohen
                                             Sentencing is adjourned to April 29, 2022 at 11 a.m.
MIC/gmf
                                             Sentencing submission deadlines are extended accordingly.
                                             SO ORDERED.
Cc: A.U.S.A. Danielle Kudla (via ECF)
    Mr. Elvin German (via email)
                                                                                  3/30/2022

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