Mikhlyn et al v. Bove et al

Filing 173

Letter Supplementing the Notice of Appearance by Anna Bove Collections, Inc., Anna Bove Company, LLC, Anna Bove Embroidery Supplies, Inc. (Berger, Peter)

Mikhlyn et al v. Bove et al

Doc. 173

Attorney at Law 250 West 57th Street Suite 1931 New York, New York 10107 Tel.: [phone] Fax.: [phone]

Richard H. Rosenberg

July 17, 2006,

Hon. Dora I. Irizarry. United States District Court Judge Eastern District of New York 225 Cadman Plaza East Brooklyn, New York 11201 Re: United States v. Isaac Almanzar et al 05 Cr 623 (DLI) Dear Judge Irizarry: I am writing on behalf of all defense counsel in the above-referenced matter to advise the court of the progress of plea negotiations and to request, with the concurrence of the government by Assistant United States Attorney Colleen Kavanagh, that the August 1, 2006 court date be held as a status conference date rather than a date for hearings on outstanding motions. Over the past weeks defense counsel have had group co-defendant meetings at the MDC, individual meetings with our respective clients, as well as group and individual plea discussions with Ms. Kavanagh. As a result of these continuing efforts by the parties substantial progress has been made towards resolution of the case on a "global" basis. Accordingly, it is respectfully suggested that the interests of justice and judicial economy will best be served by having August 1, 2006 serve as a status date.

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Thank you for your consideration to this request. Very sincerely, Richard H. Rosenberg cc.: AUSA Colleen Kavanagh, Esq. Sam Gregory, Esq. Sally Butler, Esq. Scott Fenstermaker, Esq. Barry S. Turner, Esq. John Burke, Esq.