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Letter to Judge Ramos, Re: United States v. Elvin German, 21 Cr. 245 (ER) (Dkt. 26, S.D.N.Y.)

Summary

In this September 1, 2021 letter to Judge Edgardo Ramos, filed in the Southern District of New York as Document 26 in United States v. Elvin German, 21 Cr. 245 (ER), defense counsel Mark I. Cohen requests a 30-day adjournment of the September 10, 2021 pretrial conference. Cohen writes that this is the defense's third adjournment request, that A.U.S.A. Danielle Kudla consents for the Government, and that the Government provided a proposed plea agreement on August 28, 2021 that needs review and possible further negotiation. The letter asks for a status conference the week of October 4, 2021 and raises no objection to excluding time under the Speedy Trial Act. The judge's endorsement, dated 9/2/2021, reads that the request is GRANTED, adjourns the conference to October 2021 at 3:30pm and grants the exclusion of speedy trial time.

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Full text

                Case 1:21-cr-00245-ER Document 26 Filed 09/02/21 Page 1 of 1




                                                                                   September 1, 2021

VIA ECF
The Honorable Edgardo Ramos                                                      The request is GRANTED. The September 10,
United States District Judge                                                     2021 conference is adjourned to October , 2021 at
Southern District of New York                                                    3:30pm. The request to exclude speedy trial time
40 Foley Square                                                                  until October , 2021 is GRANTED. It is SO
                                                                                 ORDERED.
New York, New York 10007

                                     Re: United States v. Elvin German
                                         21 Cr. 245 (ER)                                                 9/2/2021

Dear Judge Ramos:
        Please recall that I represent Mr. Elvin German in his defense of the above-referenced
matter. Mr. German is presently scheduled to appear before Your Honor on September 10, 2021 at
10:00 a.m. for a pretrial conference. For the reasons that follow, I write to respectfully request that
Your Honor grant a 30-day adjournment of the pretrial conference. This is the defense’s third
adjournment request in this matter. I have conferred with A.U.S.A. Danielle Kudla, and the
Government consents to this request.
        As Your Honor is aware, the parties have been engaging in good faith negotiations towards
a possible resolution of this matter, and this past Saturday, August 28, 2021, the Government
provided the defense with a proposed plea agreement. The requested adjournment is necessary to
enable me to thoroughly review the proposed plea agreement with Mr. German and to possibly
further negotiate the offer.
        Therefore, I write to respectfully request that Your Honor grant a 30-day adjournment of the
pretrial conference in the above-captioned matter. The parties respectfully request that the Court
schedule a status conference for the week of October 4, 2021, or a date convenient to the Court
thereafter, and if the parties come to an agreement beforehand, we will notify Chambers to seek a
change of plea hearing date.1 The defense has no objection to the exclusion of time under the
Speedy Trial Act. Thank you for your consideration.
                                                                        Respectfully submitted,


                                                                        Mark I. Cohen, Esq.

MIC/gmf

Cc: A.U.S.A. Danielle Kudla (via ECF)
    Mr. Elvin German (via email)

1
    I am unavailable to appear from October 6 through October 13, 2021 for personal reasons.

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