Case 1:16-cr-00632-VEC Document 64 Filed 09/24/18 Page 1 of 2

September 24, 2018 Orrick, Herrington & Sutcliffe LLP

51 West 52nd Street
Via ECF New York, NY 10019-6142
+1 212 506 5000
orrick.com
Honorable Valerie E. Caproni
United States District Court
Southern District of New York Savannah Stevenson
40 Foley Square, Courtroom 443
E sstevenson@orrick.com
New York, New York 10007 D +1 212 506 3704
F +1 212 506 5151

Re: United States v. Todd R. Howe, 16-CR-632 (VEC)

Dear Judge Caproni:

We represent Todd Howe in the above-referenced matter. We write on behalf of Mr.

Howe and the Government to jointly request an extension of the Probation Department’s
timetable to complete its presentence investigation.

We received the first disclosure of Mr. Howe’s presentence investigation report (“PSR”)
on September 12, 2018. Objections to the draft PSR are due tomorrow, September 25, 2018.
This timetable was set in relation to Mr. Howe’s original sentencing control date of November 3,
2018.

In light of the Court’s adjournment of Mr. Howe’s sentencing control date to January 4,
2019 (ECF Dkt. No. 63), and the Court’s request that the parties provide further information
regarding whether Howe defrauded his credit card company on or about October 28, 2016 (ECF
Dkt. No 57), counsel for the defense and the Government respectfully request an extension of the
presentence investigation timetable. The requested extension will allow time for counsel to work
through issues related to Mr. Howe’s remand in March 2018, and will allow time for two more
sentencings of defendants against whom Mr. Howe testified, Braith Kelly and Steven Aiello, to
be completed in advance of the final PSR disclosure deadline. After conferring with the
Probation Department, we jointly request the following timetable extension:

 Objections to the PSR due November 5, 2018

 Final PSR disclosure due December 4, 2018
 Sentencing date of January 4, 2019 (remains a control date)

The proposed timetable is acceptable to all interested parties and will provide the
Probation Department and the Court with equal or more time to prepare and review the final
PSR.
* * *
 Case 1:16-cr-00632-VEC Document 64 Filed 09/24/18 Page 2 of 2

September 24, 2018

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Counsel for Mr. Howe and the Government are available at the Court’s convenience
should it wish to discuss this request or any related issue.

Respectfully submitted,

ORRICK, HERRINGTON & SUTCLIFFE, LLP

BY: _______________________________
Savannah Stevenson