Case 15-2684, Document 54, 10/31/2016, 1895683, Page1 of 2
LAW OFFICE OF 

MICHAEL K. BACHRACH 
276 FIFTH AVENUE, SUITE 501 
NEW YORK, N.Y. 10001 
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TEL. (212) 929‐0592 •  FAX. (866) 328‐1630 
 
 

 
 

MICHAEL K. BACHRACH * 
* admitted in N.Y., MN and D.C. 

http://www.mbachlaw.com 
michael@mbachlaw.com 

October 31, 2016
By ECF
Catherine O’Hagan Wolfe, Clerk of the Court
Second Circuit Court of Appeals
40 Foley Square
New York, NY 10007
Re: United States v. Agron Hasbajrami,
15-2684 (2d Cir.)
Dear Ms. Wolfe:
I, along with Joshua L. Dratel and Steve Zissou, represent Defendant-Appellant Agron
Hasbajrami in the above-referenced matter. I write to update this Court on the status of the instant
appeal.
On February 25, 2016, this Court issued an order granting Appellant’s motion to hold the
case in abeyance pending the disclosure to Appellant’s counsel of a classified opinion that relates
to the instant appeal and that had been issued by the District Court, but not at the time disclosed to
Appellant’s counsel. Said classified opinion, issued by the Honorable John Gleeson shortly before
he retired from the bench, has since been disclosed to the undersigned in redacted form. Upon
information and belief, the redactions have been made available to the Government, but not to
Appellant’s counsel. As a result, we filed a motion in the District Court requesting a fully
unredacted copy of Judge Gleeson’s opinion. Since we have the requisite national security
clearance to review the redactions in question (provided the District Court determines that we have
a “need to know” the portions of the opinion in question), we have consented to receiving the
unredacted brief subject to the requirements of the Classified Information Procedures Act, 18
U.S.C. Art. 3.
In light of Judge Gleeson’s retirement from the bench, Appellant’s motion was initially
reassigned to the Honorable Margo K. Brodie, United States District Court Judge for the Eastern
District of New York, and then reassigned again to the Honorable Dora L. Irizarry, Chief Judge of
United States District Court for the Eastern District of New York. The motion has been fully
briefed by all parties and remains sub judice before Chief Judge Irizarry.
Once Chief Judge Irizarry rules on our motion, we estimate that we will need
approximately 30-45 days from that date to then update, finalize, and file Mr. Hasbajrami’s

 Case 15-2684, Document 54, 10/31/2016, 1895683, Page2 of 2
Catherine O’Hagan Wolfe, Clerk of the Court
October 31, 2016
Page 2 of 2
 

Opening Brief on Appeal. We will write this Court again with a further status update in 90 days,
or when Chief Judge Irizarry rules on our underlying motion, whichever is sooner.
Respectfully submitted,
/S/
Michael K. Bachrach
Attorney for Defendant-Appellant
Agron Hasbajrami
MKB/mb
cc: All parties of record (by ECF)