Case 3:23-cr-00118-GC Document 23 Filed 10/06/23 Page 1 of 2 PageID: 288
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`The Legal Center
`One Riverfront Plaza
`Newark, New Jersey 07102
`Tel: (973) 643-7000
`Fax (973) 643-6500
`
`Joseph B. Shumofsky, Esq.
`Member
`Direct Dial: 973-643-5382
`Email: jshumofsky@sillscummis.com
`
`101 Park Avenue
`28th Floor
`New York, NY 10178
`Tel: (212) 643-7000
`Fax: (212) 643-6500
`
`October 5, 2023
`
` It is SO ORDERED on this
` 6th day of October, 2023.
`
`VIA EMAIL
`Honorable Georgette Castner
`Clarkson S. Fisher Building & U.S. Courthouse
`402 East State Street
`Trenton, NJ 08608
`(c/o Ann Dello Iacono at Ann_Dello_Iacono@njd.uscourts.gov)
`
` /s/Georgette Castner
` GEORGETTE CASTNER, USDJ
`
`Re: United States v. Sahni, 23-CR-118
`
`Dear Judge Castner,
`
`Thank You for Your Honor’s time this morning to speak with the parties regarding
`sentencing issues in the above-referenced case.
`
`Upon further consideration, we respectfully request permission to file our application for
`authority to subpoena records under Rule 17(c)(3) until we receive the Government’s sentencing
`memorandum on October 19, 2023. As discussed during the call this morning, in large part, the
`Defendant’s need for certain records and information will be based on the scope of the
`Government’s arguments and the facts supporting those arguments. As such, to avoid (i) the need
`to make a supplemental application to this Court if we identify additional records required to
`fairly address certain arguments or alleged facts and (ii) any attendant delay a supplemental
`application would cause, we would like to file our motion on October 23, shortly after the
`Government submits its sentencing memorandum on October 19.
`
`Affording the Defense the ability to review the Government’s submission prior to filing
`its motion not only would save the possibility of potentially needing to file a second motion, but
`also may eliminate the need for the request altogether. During the call today, the Government
`questioned the probative need for the Defense to subpoena records. Following a review of the
`Government’s submission, the Defense may reach the same conclusion or, at least, may narrow
`the scope of its request.
`
`

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`Case 3:23-cr-00118-GC Document 23 Filed 10/06/23 Page 2 of 2 PageID: 289
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`Honorable Georgette Castner
`October 5, 2023
`Page 2
`
`Thank You for Your Honor’s consideration of this request.
`
`Respectfully submitted,
`
`/s/ Joseph B. Shumofsky
`
`Joseph B. Shumofsky
`
`cc:
`
`Sophie Reiter, AUSA
`
`