Opinion
Case No.: 2:11 cr 879
02-28-2012
USA v. Byron Zabala
HOWARD W. BAILST
CERTIFIED BY THIS SUPREME COURT OF
NEW JERSBY AS A CKIMIXAJ. TRIAL ATTORNEY
MICHAEL A. OROZOO
ADMITTED IN NY & NJ
THE NATIONAL, NEWARK BUILDING
744 BROAD STREET, SUITE 1901
NEWARK, N.J. 07102
PHONI: 973-693-4408
FAX: 973-735-2719
TERENI-B STSICU
ADMITTED IN NY & NY
MATTSSW BRYANT, *OFOOI.N-OKI.?
"MKMIIRK OF NISW YORK BAR
100 CHURCH STREET
8TH FLOOR, PMB 1018
NEW YORK, NEW YORK 10007
WBB: WWW.BOLEa-AIj.COM
Via Hand Delivery and ECF
United States District Court
for the District of New Jersey
Attn: Honorable Jose L. Linares
50 Walnut Street
Newark, NJ 07102
Dear Judge:
My office is requesting additional time of at least two weeks until March 13, 2012 in order to have my client undergo additional psychological testing with both Dr. Simring and Dr. Hasson. Last Friday, Dr. Simring and I met with my client and he was interviewed for nearly three hours. Dr. Simring has determined that additional psychological testing by Dr. Hasson is necessary m order to make a final diagnosis. He cannot render an opinion without such testing.
I spoke to Dr. Hasson who informed me he is unavailable to see my client until next Wednesday March 5, 2012. In order to accommodate Dr. Hasson's schedule and an additional visit by Dr. Simring to interview my client again, I am requesting an additional two weeks. It is my understanding that, even with the above explanation, the Government is objecting to this
Sincerely,
_________________
Michael Orozco
MAO/mao
cc: United States Attorneys Office (Via Electronic Mail)