Case 3:23-cr-00118-GC Document 40 Filed 09/03/24 Page 1 of 2 PageID: 331
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`The Legal Center
`One Riverfront Plaza
`Newark, New Jersey 07102
`Tel: (973) 643-7000
`Fax (973) 643-6500
`
`Richard J. Sapinski, Esq.
`Member
`Direct Dial: 973-643-5975
`Email: rsapinski@sillscummis.com
`
`101 Park Avenue
`28th Floor
`New York, NY 10178
`Tel: (212) 643-7000
`Fax: (212) 643-6500
`
`August 23, 2024
`
`VIA EMAIL
`Honorable Georgette Castner
`Clarkson S. Fisher Building & U.S. Courthouse
`402 East State Street
`Trenton, NJ 08608
`(c/o Jamie Quinn at jamie_quinn@njd.uscourts.gov)
`
`A telephone conference is hereby set for
`September 5, 2024, at 10:00 a.m.
`
`The Court will provided dial-in information
`via email.
`
`SO ORDERED
`on this 3rd day of September, 2024.
`
`Re: United States v. Sahni, 23-CR-118
`
`__________________________
`Hon. Georgette Castner, U.S.D.J.
`
`Dear Judge Castner,
`
`The parties’ sentencing memoranda in connection with the above-referenced case are
`now fully submitted to the Court. As we approach the September 11, 2024 sentencing hearing,
`we write to respectfully request a telephone conference with Your Honor and the Government to
`address the logistics of the hearing.
`
`As the Court is aware, there are several contested Guidelines enhancements and disputed
`factual issues to be considered at sentencing. As we have raised previously with the Court, the
`defense intends to introduce testimony probative of those issues during the hearing, including the
`testimony of:
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`
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`
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`One or more expert neurologists to opine on and contest the application of the six-
`point enhancement under § 2L1.1(b)(6);
`
`One or more fact witnesses, including Carla Pedro, who regularly interacted with
`JK and HK at the Sahnis’ homes and in other social settings, in connection with
`the Court’s consideration of the § 3553(a) factors.
`
`Accordingly, so that the parties may prepare appropriately for sentencing, we respectfully
`request a conference with the Court to understand Your Honor’s preferences as to the
`presentation of evidence and other logistical aspects of the hearing.
`
`

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`Case 3:23-cr-00118-GC Document 40 Filed 09/03/24 Page 2 of 2 PageID: 332
`
`Honorable Georgette Castner
`August 23, 2024
`Page 2
`
`Thank You for Your Honor’s consideration of this request.
`
`Respectfully submitted,
`
`/s/ Richard J. Sapinski
`Richard J. Sapinski
`
`Cc: AUSA Andrew Kogan
`
`