Case 1:19-cr-00789-PGG Document 917 Filed 08/29/22 Page 1 of 2
`BEYS LISTON & MOBARGHA LLP
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`Joshua D. Liston
`646.755.3601 (Direct)
`jliston@blmllp.com
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`August 29, 2022
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`Via ECF
`Hon. Paul G. Gardephe, District Judge
`United States District Court for the
`Southern District of New York
`Thurgood Marshall U.S. Courthouse
`40 Foley Square
`New York, NY 10007
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` Re: USA v. Rose (Jelani Wray), Case No. 19-cr-00789-PGG-2
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`Dear Judge Gardephe:
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`On April 8, 2022, the Court sentenced my client, Jelani Wray, to seven years’ incarceration,
`and ordered that he surrender to begin serving his sentence on July 8, 2022. On July 7, the Court
`granted Mr. Wray’s request to extend his surrender date until September 8, so that he could continue
`to care for his wife, who is in the midst of a high-risk pregnancy and is currently being evaluated to
`determine whether she has breast cancer. In light of additional developments since Mr. Wray’s last
`request, I respectfully request further extension of Mr. Wray’s time to surrender, so that he can
`begin serving the sentence on January 5, 2023. Mr. Wray and I affirm that he will not seek another
`extension. I have spoken with AUSA Louis Pellegrino, and the government consents to this
`application.
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`As the Court may recall, Janai Jackson, Mr. Wray’s wife, was six weeks pregnant at the time
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`of sentencing, with a high-risk pregnancy. In 2021, she had suffered four miscarriages and two
`surgical procedures. Following Mr. Wray’s sentencing, the couple learned that she was pregnant
`with twins but that one of the babies did not survive, which complicates the pregnancy even further.
`In addition, earlier this summer, Ms. Jackson developed a hard mass in her right armpit. She went
`to the doctor on July 2, and, in part because of Ms. Jackson’s family history of breast cancer, the
`doctor ordered an ultrasound examination and a biopsy of the mass.
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`By way of update, Ms. Jackson’s pregnancy is now even higher risk as a result of additional
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`complications. As shown in the attached medical records, she has developed growing fibroids,
`which are abnormal growths that develop in or on a woman’s uterus, and a recent ultrasound shows
`a marginal placenta, meaning that the placenta is close to the opening of the cervix but doesn’t cover
`it. (Attachment 1 (Letter from Women for Women Obstetrics and Gynecology (Aug. 9, 2022).)
`The fibroids have caused Ms. Jackson significant pain and she has been admitted to the hospital as a
`result, as the pain resembles pre-term labor. (Attachment 2 (Long Island Jewish Hospital Discharge
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`641 Lexington Avenue, 14th Floor, New York, NY 10022
`Main: 646.755.3600
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`Case 1:19-cr-00789-PGG Document 917 Filed 08/29/22 Page 2 of 2
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`Page 2 of 2
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`Papers (July 26, 2022).) She then was put on bed rest following her discharge. The marginal
`placenta places the baby’s nutrition and potential weight. Both issues have increased the likelihood
`of a pre-term labor. Ms. Jackson’s due date is December 5, 2022.
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`With respect to the hard mass that developed under Ms. Jackson’s armpit, the mass will be
`surgically removed. She is expected to have the biopsy surgery on September 28. (Attachment 3
`(Letter from Roland R. Purcell, M.D. (Aug. 24, 2022).) A recent ultrasound revealed both that the
`mass in her armpit is growing and a newly found cyst in her right breast. Ms. Jackson will have a
`mammogram and the upcoming biopsy will determine if it is cancerous. There is a family history
`present: Ms. Jackson’s grandmothers suffered from breast cancer and lymph node cancer. Ms.
`Jackson herself had a mass was removed when she was teenager.
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`Mr. Wray seeks this extension of his surrender date until shortly after the baby’s due date for
`compassionate reasons. As his wife is on bed rest, Mr. Wray is taking care of everything for her,
`both emotionally and physically, to help her through all of the pregnancy complications and her
`current cancer scare, including her upcoming appointments for both issues. Furthermore, it is
`unlikely that Ms. Jackson will be able to give birth in the future, further underscoring the importance
`to them of ensuring the safe delivery of this child. During any additional time granted before his
`report date, Mr. Wray will continue to devote all of his time to his family and to make sure that they
`will be relatively provided for during his incarceration.
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`Thank you for your attention to this application.
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`cc.: All counsel of record (via ECF)
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`Respectfully submitted,
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`/s/ Joshua D. Liston
`Joshua D. Liston
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