Letter to Judge Ramos Re: United States v. Elvin German and Vanessa Gomez, 21 Cr. 245 (ER) (Dkt. 20, S.D.N.Y.)
Summary
A letter dated June 18, 2021 from Mark I. Cohen, counsel for Elvin German, to Judge Edgardo Ramos in United States v. Elvin German and Vanessa Gomez, 21 Cr. 245 (ER), in the Southern District of New York. It asks for a 45-day adjournment of the June 23, 2021 pretrial conference, the defense's first adjournment request, with the consent of A.U.S.A. Danielle Kudla and co-counsel Lorraine Belostock. The letter says the defense has received approximately 300 GB of discovery materials, much of it within approximately the last two weeks, and expects the Government to produce more. The Court's endorsement, so ordered 6/22/2021, adjourns the conference to August 6, 2021 at 3:30 p.m. and excludes speedy trial time from June 23, 2021 until August 6, 2021 in the interest of justice.
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Full text
June 18, 2021
The June 23, 2021 conference is adjourned to August 6, 2021
VIA ECF at 3:30 p.m. Speedy trial time is excluded for June 23, 2021,
The Honorable Edgardo Ramos until August 6, 2021, in the interest of justice.
Senior District Court Judge
SO ORDERED.
Southern District of New York
40 Foley Square
New York, New York 10007 6/22/2021
Re: United States v. Elvin German and Vanessa Gomez
21 Cr. 245 (ER)
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 June 23, 2021 at
3:30 p.m. for a pretrial conference. For the reasons that follow, I write to respectfully request that
Your Honor grant a 45-day adjournment of the pretrial conference. This is the defense’s first
adjournment request in this matter. We have conferred with A.U.S.A. Danielle Kudla and co-
counsel Ms. Lorraine Belostock, Esq., and both parties consent to this request.
The defense is in receipt of voluminous discovery in this matter, much of which has been
provided to us within the last approximately two weeks. Thus far, we have received
approximately 300 GB of discovery materials, and we anticipate that the Government will be
producing more discovery in the near future. The defense has been working diligently to review
the discovery has been provided to us, but due to the volume, we do not expect to complete this
review until after June 23, 2021.
Therefore, I respectfully request a 45-day adjournment of the pretrial conference in the
above-captioned matter in order to enable the defense to complete its review of the voluminous
discovery in this matter. 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)
Ms. Lorraine Belostock, Esq. (via ECF)
Mr. Elvin German (via email)
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