`
`Law Offices of Ezra Spilke
`
`--11
`
`11
`
`£-1&~ 1·
`
`1825 Foster Avenue, Suite I K
`Brooklyn, New York I 1230
`t: (718) 783-3682
`e: ezra@spilkelaw.com
`www.spilkelaw.com
`
`May 15, 2024
`
`ByECF
`The Honorable Lewis A. Kaplan
`United States District Court
`Southern District of New York
`500 Pearl Street
`New York, New York 10007
`
`Re: United States v. Chanette Lewis et al., No. 21 Cr. 729
`Client: Tatiana Daniel
`
`Dear Judge Kaplan:
`
`With the consent of the government and of Pretrial Services, I write to
`respectfully request a 30-day extension of the June 6, 2024, surrender date.
`
`The Bureau of Prisons has yet to inform Ms. Daniel of the facility to which
`she is to report. Moreover, Ms. Daniel is trying to earn as much money as she can to
`fund her commissary account while she is incarcerated. Many if not most people in
`BOP custody have family or other supporters add money to their commissary
`account. Ms. Daniel does not have anyone who can or will do that for her, and she
`reports that she was unable to work for approximately two weeks in April due to a
`flu-like illness and has, thus, lost some of the earnings that she was relying upon. A
`later surrender date would provide Ms. Daniel with the opportunity to gather the
`necessary financial resources to better equip her for her term of imprisonment.
`
`Accordingly, we respectfully request that the Court grant Ms. Daniel an
`extension of her surrender date to July 8, 2024. I have conferred with AUSA
`Michael Neff and Pretrial Services Officer Christina Venable, who both inform me
`that neither the government nor Pretrial Services object to this request. The Court's
`considerate attention to this matter is greatly appreciated.
`
`Respectfully submitted,
`
`lJ~~
`
`Ezra Spilke
`
`cc:
`
`Tatiana Daniel, by email
`AUSA Michael Neff, by ECF
`Christina Venably, Pretrial Services, by email
`
`

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