Case 3:23-cr-00118-GC Document 38 Filed 07/11/24 Page 1 of 2 PageID: 328
`
`Sills Cummis & Gross
`
`
`A Professional Corporation
`
`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
`
`July 10, 2024
`
`VIA ECF and EMAIL
`
`
`Honorable Georgette Castner
`
`
`
`Clarkson S. Fisher Building & U.S. Courthouse
`402 East State Street
`
`Trenton, NJ 08608
`(c/o Jamie Quinn atjamie_quinn@njd.uscourts.gov)
`
`
`
`Re: United States v. Sahni, 23-CR-118
`
`
`
`
`
`Dear Judge Castner,
`
`On behalf of our client, Dr. Sahni, we write to respectfully ask this Court to reconsider
`
`
`
`
`
`
`
`our request for a two-day extension of time to submit our sentencing memorandum, from
`
`
`
`Wednesday, July 24 to Friday, July 26, 2024, considering that sentencing has been scheduled for
`
`
`
`
`
`September 11, 2024 (later than when the Court originally had anticipated during our status call).
`
`
`
`
`We are mindful of the Court's interest in moving this matter toward conclusion and appreciate
`
`
`
`
`
`Your Honor's understanding that the defendant's sentencing memorandum is a critical
`
`
`
`
`
`
`submission for the Court's consideration. The modest extension requested herein is important to
`
`
`
`
`
`
`our and relevant issues and also complete address all material ensure we are able to sufficiently
`
`
`
`
`review (and utilize, as warranted) the subpoenaed records, some of which we just received (and
`
`
`others still are forthcoming).
`
`We are aware that, during the June 26, 2024 status conference, Your Honor was not
`
`
`
`
`
`
`
`
`
`
`inclined to grant defense counsel's request for a deadline of Friday, July 26, rather than
`
`
`
`Wednesday, July 24, based upon an anticipation that a sentencing date would be set for the last
`
`
`
`week of August or first week of September. As the sentencing hearing now has been set for
`
`
`September 11, the following week, it is our hope that the requested additional two days to submit
`
`
`
`the Court. inconvenience our sentencing memorandum would not greatly
`
`As we referenced during the June 26, 2024 status call, we still are receiving subpoena
`
`
`
`
`
`
`
`returns, despite all diligent efforts over the last few months to obtain such records sooner.
`
`

`

`Case 3:23-cr-00118-GC Document 38 Filed 07/11/24 Page 2 of 2 PageID: 329
`
`Sills Cummis & Gross
`
`
`A Professional Corporarion
`
`Honorable Georgette Castner
`
`
`
`July 10 , 2024
`Page2
`
`Indeed, just yesterday, we received additional records from Wilson Sonsini, counsel for Ms.
`
`
`
`
`
`
`
`
`
`
`
`
`Kaur (following their redactions of certain information pursuant to the Court's prior order). Also,
`
`
`
`and as mentioned to the Court during our recent call, both Mr. Sapinski and I have pre-scheduled
`
`
`
`
`
`is memorandum currently vacations upcoming in July between now and when the sentencing
`
`
`
`due. As such, we would very much appreciate having an additional two days until the end of the
`
`
`
`
`
`
`week (July 26, instead of July 24) to complete Dr. Sahni's submission, an essential part of the
`sentencing process.
`
`We have solicited the Government's position on this request. Mr. Kogan advised that the
`
`
`
`
`
`
`
`
`
`Government has no objection, so long as the Government's deadline to submit a reply also is
`
`extended by two days, from August 14 to August 16, 2024.
`
`
`
`Thank You for Your Honor's consideration of this request.
`
`
`
`REQUEST GRANTED
`
`
`
`Respectfully submitted,
`
`SO ORDERED on this 11th day of July, 2024
`
`_____________________________
`Hon. Georgette Castner, U.S.D.J.
`
`Cc: AUSA Andrew Kogan
`
`Isl Joseph B. Shumofsky
`
`
`Joseph B. Shumofsky
`
`