Case 1:14-cr-00248-PKC-RML Document 114 Filed 08/27/15 Page 1 of 2 PageID #: 846

www.MNRLawFirm.com

August 27, 2015

By ECF
The Honorable Pamela K. Chen
United States District Judge
Eastern District of New York
United States Courthouse
225 Cadman Plaza East
Brooklyn, New York 11201
Re:

United States v. Michael Grimm

Criminal Docket No. 14-248 (PKC)

Dear Judge Chen:

On July 21, 2015, Defendant Michael Grimm was sentenced by this Court for a term of
imprisonment of eight (8) months, after having pleaded guilty to one count under 26 U.S.C.
7206(2), Aiding and Assisting in the Preparation of False and Fraudulent Tax Returns.
Mr. Grimm is currently ordered to surrender to the U.S. Bureau of Prisons by 12:00 p.m.
on September 10, 2015. At this time, Mr. Grimm has been designated to FCI McKean.
Mr. Grimm asks for the Courts authorization to briefly delay his self-surrender by an
additional twelve (12) days in order to have a surgical procedure performed. The first available
appointment for this procedure is September 9, 2015. The procedure entails a brief healing period
and a second appointment to have sutures removed.
Counsel represents that it has received a letter from Mr. Grimms physician, noting the first
available appointment of September 9, 2015. Upon request, a copy of this letter can be provided
to the Court.

MIAMI OFFICE
One Biscayne Tower
2 South Biscayne Boulevard, Suite 1750, Miami 33131

FORT LAUDERDALE OFFICE

One Financial Plaza
100 Southeast Third Avenue, Suite 805, Ft Lauderdale 33394

Case 1:14-cr-00248-PKC-RML Document 114 Filed 08/27/15 Page 2 of 2 PageID #: 847

If approved, Mr. Grimm will be required to report to the Bureau of Prisons by September
22, 2015.
Assistant United States Attorney James Gatta does not oppose the relief sought.

Respectfully submitted,
/s DANIEL L. RASHBAUM
Jeffrey A. Neiman
Daniel L. Rashbaum
MARCUS NEIMAN & RASHBAUM LLP
100 Southeast Third Avenue, Suite 805
Fort Lauderdale, Florida 33394
Counsel for Mr. Grimm

Cc:

Clerk of the Court (PKC)(by ECF)