ORDER TO CONTINUE IN THE INTEREST OF JUSTICE as to Herode Chancy, Michael Albarella,… — USA v. Chancy et al (Dkt. 16)

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This is an Order of Continuance in United States of America v. Herode Chancy, Michael Albarella and Adedayo Ilori (20 Mag. 2482), with Document 16 in Case 1:20-cr-00378 filed 04/03/20. It finds the defendants were charged in a complaint dated March 3, 2020, arrested March 4, 2020 and released on bail. At the Government's request, with defense counsel's consent, in light of the corona virus pandemic, it grants a 30-day continuance until May 4, 2020 for filing an indictment or information. The order attaches the supporting affirmation of Assistant United States Attorney Cecilia E. Vogel.

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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
-------------------------------------------------------X 
UNITED STATES OF AMERICA 
v. 
HERODE CHANCY, 
MICHAEL ALBARELLA 
and ADEDAYO ILORI, 
Defendants. 
-------------------------------------------------------X 
Order of Continuance 
20 Mag. 2482 
Upon the application of the United States of America and the affirmation of Cecilia E. 
Vogel, Assistant United States Attorney for the Southern District of New York, it is found that the 
defendants were charged with violation of Title 18, United States Code, Sections 1343, 1349, 
1208A, 1956(h), 215(a) in a complaint dated March 3, 2020, and the defendants were arrested on 
March 4, 2020; 
It is further found that on March 4, 2020, the defendants were presented before Magistrate 
Judge Kevin Nathaniel Fox and released on bail, and each defendant waived his right to be charged 
in an indictment or information for 30 days; 
It is further found that the Government has requested a continuance of 30 days in light of 
the ongoing corona virus pandemic and national emergency and that the defendants, through 
counsel, have each consented that such a continuance may be granted for that purpose and have 
each specifically waived their right to be charged in an indictment or information for an additional 
30 days; and 
It is further found that the granting of such a continuance best serves the ends of justice 
and outweighs the best interests of the public and the defendant in a speedy trial; and therefore it 
is  
Case 1:20-cr-00378-LJL     Document 16     Filed 04/03/20     Page 1 of 4

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ORDERED that the request for a continuance pursuant to 18 U.S.C. § 3161(h)(7)(A) is 
hereby granted until May 4, 2020, and that a copy of this Order and the affirmation of Assistant 
United States Attorney Cecilia E. Vogel be served by email on this date on counsel for the 
defendants by the United States Attorney’s Office. 
Dated: New York, New York 
April ____, 2020 
_____________________________________ 
UNITED STATES MAGISTRATE JUDGE 
SOUTHERN DISTRICT OF NEW YORK 
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Stewart D. Aaron
Case 1:20-cr-00378-LJL     Document 16     Filed 04/03/20     Page 2 of 4

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
---------------------------------------------------------X 
UNITED STATES OF AMERICA 
v. 
HERODE CHANCY, 
MICHAEL ALBARELLA 
and ADEDAYO ILORI, 
Defendants. 
-------------------------------------------------------X 
Affirmation in Support of 
Application for Order of Continuance 
20 Mag. 2482 
State of New York 
 
) 
County of New York  
: ss.: 
Southern District of New York 
) 
CECILIA E. VOGEL, pursuant to Title 28, United States Code, Section 1746, hereby 
declares under penalty of perjury: 
1. I am an Assistant United States Attorney in the Office of Geoffrey S. Berman, United
States Attorney for the Southern District of New York.  I submit this affirmation in support of an 
application for an order of continuance of the time within which an indictment or information 
would otherwise have to be filed, pursuant to 18 U.S.C. § 3161(h)(7)(A). 
2. The defendants were charged in a complaint dated March 3, 2020, with violation of Title
18, United States Code, Sections 1343, 1349, 1208A, 1956(h), 215(a).  The defendants were 
arrested on March 4, 2020, and presented before Magistrate Judge Kevin Nathaniel Fox that same 
day.  Each of the defendants was released on bail and each defendant waived his right to be 
charged in an indictment or information for 30 days.  
3. Under the Speedy Trial Act, the Government currently has until April 3, 2020, within
which to file an indictment or information. 
Case 1:20-cr-00378-LJL     Document 16     Filed 04/03/20     Page 3 of 4

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4. Ian Marcus Amelkin, Esq., counsel for defendant Herode Chancy, David Wikstrom, Esq.
counsel for defendant Michael Albarella, and Brooke Cucinella, Esq., counsel for defendant 
Adedayo Ilori, have each consented to the Government’s request of a 30-day continuance of the 
April 3, 2020 deadline to file an indictment or information under the Speedy Trial Act in light of 
the ongoing corona virus pandemic and national emergency.    
5. Therefore, the Government is requesting, with the consent of defense counsel for each
of the defendants, a 30-day continuance until May 4, 2020.  For the reasons stated above, the ends 
of justice served by the granting of the requested continuance outweigh the best interests of the 
public and defendants in a speedy trial. 
Dated: New York, New York 
March 30, 2020 
__________________________ 
CECILIA E. VOGEL 
Assistant United States Attorney 
Tel. (212) 637-1084 
Case 1:20-cr-00378-LJL     Document 16     Filed 04/03/20     Page 4 of 4

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