USA v. Kelly
USA v. Kelly
February 1, 2022
VIA ECF:
The Honorable Ann M. Donnelly
United States District Court Judge
United States District Court, Eastern District of New York
225 Cadman Plaza East
Brooklyn, New York 11201
I write respectfully to request a final two-week extension, until February 17, 2022, in
which to file Mr. Kelly’s post-trial motions. The government does not object to this request.
Although undersigned counsel has been working diligently to complete Mr. Kelly’s post-trial
motions, several issues have arisen that demand a short extension. First, the MDC indefinitely
suspended all jail visits nearly a month ago, preventing undersigned counsel from meeting with
Mr. Kelly to review the proposed pleadings. To complicate matters, Mr. Kelly was advised that
he contracted COVID which interfered with his ability to speak with counsel by telephone.1
Undersigned counsel has arranged several zoom meetings with Mr. Kelly over the next two
weeks, but the first meeting could not be confirmed until February 3, 2022. It is vitally important
that Mr. Kelly meaningfully participate in his post-trial defense. The MDC has not indicated
when visits will resume which is less than ideal, but undersigned counsel is confident that she can
accomplish necessary discussions with Mr. Kelly via upcoming scheduled zoom visits.
Second, Mr. Kelly made the important decision of parting ways with his trial team. This
decision required serious consideration, and of course, demanded that Mr. Kelly confer with the
members of his trial team. Mr. Cannick and Mr. Scholar have already moved to withdraw from
the case. Counsels Blank-Becker and Farinella have asked that undersigned counsel sign a
substitution of counsel which they intend to file with this Court in short course. Undersigned
counsel prefers to file post-trial motions once all counsel has formally withdrawn. As such, Mr.
Kelly respectfully seeks a final extension until February 17, 2022 for the filing of his motions.
Respectfully Submitted,
/s/JENNIFER BONJEAN