Unopposed MOTION to Continue Trial by Alexandra Acosta. Responses due by 3/14/2024 — USA v. Alexandra Acosta (Dkt. 21)

Record facts

U.S. District Court for the Southern District of Florida · No. 0:23-cr-60170-RNS · Doc. 21 · 2024-02-29 · Docket on CourtListener

Summary

An Unopposed Motion to Continue filed February 29, 2024 as Doc. 21 in United States v. Alexandra Acosta, No. 0:23-cr-60170-RNS, in the U.S. District Court for the Southern District of Florida. Defense counsel Brian Silber asks the court to move the calendar call set for March 5, 2024 and the trial set for March 11, 2024 to a date after April 1, 2024, and states that AUSA Trevor Jones has no objection. The motion recounts that the defendant was arraigned on October 19, 2023, that the government made its first discovery disclosure on October 25, 2023, and that the court granted a first continuance on November 20, 2023. As grounds it cites a scheduling conflict for defense counsel and ongoing discovery, including third-party subpoena documents from a company named Scratch that counsel expects to contain IP address information. It states both counsel are available for trial in April and May.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Full text

IN THE UNITED STATES DISTRICT COURT 
 
FOR THE SOUTHERN DISTRICT OF FLORIDA 
 
 
UNITED STATES OF AMERICA, ) 
 
 
 
 
 
 
) 
 
 
Plaintiff, 
 
 
) 
 
 
 
 
 
 
 
) 
v. 
 
 
 
 
 
) 
 
CASE NO. 23-cr-60170-RNS 
 
 
 
                              ) 
 
 
 
 
 
 
 
) 
 
ALEXANDRA ACOSTA,   
 
) 
 
 
 
 
 
 
) 
 
 
Defendant.  
 
) 
_______________________________) 
 
UNOPPOSED MOTION TO CONTINUE 
 
COMES NOW, the Defendant, ALEXANDRA ACOSTA (“Acosta”), by and 
through the undersigned attorney, and motions this Court to continue her presently 
scheduled calendar call and trial for a date after April 1, 2024. In support thereof, 
Acosta states as follows: 
1. 
Prior to filing the instant motion, the undersigned communicated with 
AUSA Trevor Jones (“AUSA Jones”), the prosecutor assigned to the instant case, 
who advised the government has no objection to granting the instant motion.  
2. 
On October 19, 2023 Acosta was arraigned. On October 25, 2023, the 
government disclosed its first discovery submission. On November 20, 2023, the 
Case 0:23-cr-60170-RNS   Document 21   Entered on FLSD Docket 02/29/2024   Page 1 of 3

Court granted Acosta’s first motion to continue. Calendar call is presently scheduled 
for March 5, 2024 and trial is set for March 11, 2024. 
3. 
The parties require a second continuance for two reasons: First, the 
undersigned attorney is getting married on March 10, 2024 and is unable to properly 
prepare for trial because trial in the instant case is scheduled for the next day, March 
11, 2024. While the actual wedding is on March 10, the undersigned has family and 
friends coming in from out of town starting March 8, 2024. Family events will be 
taking place from March 8 through March 10. Aside from not having the time or 
state of mind to prepare for trial, the undersigned would greatly appreciate not 
having to start a trial the day after getting married.  
4. 
Second, the parties are still engaging in discovery. For instance, the 
government recently received new documents in response to subpoenas it issued to 
third parties and those items are going to be disclosed to the Defense very soon but 
have not yet been disclosed. Documents from one of the third parties (a company 
named “Scratch”) is expected to contain IP address information that the undersigned 
believes will be exculpatory and necessary for use at trial (for cross-examination of 
government witnesses and for admission during the Defense case).  
5. 
The undersigned is available for trial in April and May with the 
exception of April 22, 2024 and April 23, 2024 due to Passover observance. AUSA 
Jones has advised that he is available for trial in both April and May. 
Case 0:23-cr-60170-RNS   Document 21   Entered on FLSD Docket 02/29/2024   Page 2 of 3

WHEREFORE, the Defendant and the undersigned attorney respectfully 
motion this Court continue the presently scheduled calendar call and trial after April 
1, 2024. 
 
 
 
 
 
 
Respectfully Submitted, 
 
 
 
 
 
 
/s/ Brian Silber 
 
 
 
 
 
 
______________________________ 
 
 
 
 
 
 
Brian Silber, Esq. 
 
 
 
 
 
 
Counsel for Alexandra Acosta 
 
 
 
 
 
 
Florida Bar #:  0640646 
 
 
 
 
 
 
916 South Andrews Avenue 
 
 
 
 
 
 
Fort Lauderdale, FL 33316 
 
 
 
 
 
 
954-462-3636 (ofc) 
 
 
 
 
 
 
silberlaw@gmail.com 
 
 
 
 
 
 
briansilberlaw.com 
 
 
CERTIFICATE OF SERVICE 
 
I HEREBY CERTIFY that a copy of this document was served on the 
following parties via CM/ECF on February 28, 2024. 
 
SERVICE LIST 
 
AUSA Trevor Jones 
U.S. Attorney’s Office SDFL 
500 E. Broward Blvd, 7th Floor 
Ft. Lauderdale, FL 33394 
786-564-9109 
trevor.jones@usdoj.gov 
 
 
 
 
Case 0:23-cr-60170-RNS   Document 21   Entered on FLSD Docket 02/29/2024   Page 3 of 3

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