miguel ashby court documents

Case 211-mj-00303-MAT Document 1 Filed 062811 of 19

Case 211-mj-00303-MAT Document 1 Filed 062811 Page 2 of 19


















12132011 1330 2126893858 PAGE 02fr===========

RICHARD JASP

OEC 1 S 2011

Honorable Alvin K Hellerstcin United States District Judge Southern District ofNew York 500 Pearl Street lew York New York 10007

Re United States v Miguel Ashby 11Cr0770(AKH)

Dear Judge Hellerstein

I am the attorney fONhe defendant Miguel Ashby in the above captioned case On November 2 2011 I was appointed under the Criminal Justice Act to replace prior counsel Lee Ginsberg Esq I respectfully submit this letter to request an adjournment of the defense motion on behalf ofMr Ashby until December 212011 In the pa~t six weeks I have attempted to establish a relationship with the defendant Miguel Ashby and review the diseovery in this matter As a result of a development in the plea negotiation which occurred yesterday December 12 2011 J respectfully request additional time to file a defense motion on behalfof Mr Ashby This adjournment is not being made within the 48 hour rule established by Your Honor due specifically to a negotiation development which occurred yesterday I apologize for not being able to comply with this Courts local rule I attempted to contact the government this afternoon regarding this matter I have not been able to discuss the adjournment with the governments eounsel This is the first request ofthis nature

Respectfully slbmitted

~gt4-~sq Attorney for Miguel Ashby

cc AUSA Santosh Shankaran Aravind ~a fax (212) 6372937 and santosharandusdojgov AUSA Timothy Donald Sini viafax (212) 637middot2358 and TimotbySiniusdojgov

Case 111-cr-00770-AKH Document 82 Filed 121411 Page 1 of 1



















12132011 1330 2126893858 PAGE 02fr===========

RICHARD JASP

OEC 1 S 2011









miguel ashby court documents

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