Opinion
12cr 705 (KM)
01-08-2013
Re: USA v. Khaseem Kelly
CATHERINE M. BROWN, L.L.C. CERTIFIED BY THE SUPREME COURT OF NEW JERSEY AS A CIVIL & CRIMINAL TRIAL ATTORNEY MEMBER NJ AND PA BARS Via PACER Hon. Kevin J. McNulty, U.S.D. United States District Court Lautenberg US P.O. & Cthse.,
CATHERINE M. BROWN, L.L.C.
CERTIFIED BY THE SUPREME COURT OF NEW JERSEY
AS A CIVIL & CRIMINAL TRIAL ATTORNEY
MEMBER NJ AND PA BARS Via PACER
Hon. Kevin J. McNulty, U.S.D.
United States District Court
Lautenberg US P.O. & Cthse.,
Sentence Hearing Date: Jan. 30, 2013 Dear Judge McNulty:
My client, Mr. Kelly, is scheduled to be sentenced on Jan. 30, 2013.1 write to request an adjournment of 3 weeks. I make this request because I am scheduled to begin a civil trial in the Essex Superior Court on Jan. 14, 2013. ACBB-BITS v. Clancey Realty Group, ESX-L-93-07. As that matter is 6 years old, I expect the case to be reached in the month of January.
As that trial will take about 2 weeks, I will not be able to review timely the draft presentence report with Mr. Kelly, nor timely submit a sentencing memo to the court.
I have spoken to my client, the Probation Officer, Ms. Kimberly Artist, and with the Assistant United States Attorney, James Donnelly, about my request and all consent to it.
I appreciate the court's consideration of my request.
Respectfully submitted, Catherine M. Brown, Esq. Cc: Khaseem Kelly
James Donnelly, AUSA
Kimberly Artist, USPO
SO ORDERED
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Levin McNulty , U.S.D.J.