Correspondence re: request for postponement of motion to withdraw hearing — USA v. Qureshi (Dkt. 23, D. Md.)

Record facts

U.S. District Court for the District of Maryland · No. 1:22-cr-00330-JKB · Doc. 23 · 2023-09-13 · Docket on CourtListener

Full text

U.S. Department of Justice 
 
United States Attorney 
District of Maryland 
 
 
Paul Riley 
Suite 400 
DIRECT: 410-209-4959 
Assistant United States Attorney 
36 S. Charles Street 
MAIN: 410-209-4800 
Paul.Riley@usdoj.gov 
Baltimore, MD 21201-3119 
FAX: 410-962-3091 
 
 
 
September 13, 2023 
BY ECF 
 
 
 
 
 
 
 
 
 
The Honorable Richard D. Bennett    
United States District Judge 
United States District Court for the District of Maryland 
101 West Lombard Street 
Baltimore, MD 21201 
 
 
Re:  
United States of America v. Ayaz Qureshi, Crim. No. RDB-22-0330 
 
 
Dear Judge Bennett: 
 
I write on behalf of the Government in the above-referenced case to respectfully request 
that the Court postpone the hearing on Defendant’s Motion to Withdraw Guilty Plea, which is 
currently scheduled for October 4, 2023 at 11:00 am, for a period of six to eight weeks.   
 
Submitted in support of Defendant’s Motion to Withdraw was a purported “Competency 
Evaluation” prepared by a psychologist retained by Defendant, ECF No. 20-1, which makes 
certain conclusions about Defendant’s cognitive abilities.  Defense counsel has informed 
Government counsel that he intends to call the author of the evaluation as a witness at the motion 
to withdraw hearing.   
 
The Government intends to retain a forensic psychologist to, among other things, assess 
the evaluation and possibly prepare a report and testify at the hearing.  The requested 
postponement will afford the Government sufficient time to do so.  I have conferred with counsel 
to Defendant concerning a postponement of six to eight weeks.  He writes, “So long as you 
provide me a copy of the report, and his credentials and all requirements per discovery I have no 
opposition to it.”1 
 
Accordingly, the Government respectfully requests that the Court postpone the hearing 
currently scheduled for October 4, 2023 for a period of six to eight weeks.   
Respectfully submitted, 
 
Erek L. Barron 
United States Attorney 
 
    /s/                                                     
By: 
Paul A. Riley 
 
Assistant United States Attorney 
 
 
CC:  All Counsel (by ECF) 
 
1 The Government is of course aware of its discovery obligations and will abide by them.  But it is not clear 
at this time whether any expert retained by the Government will be a testifying expert who will generate a report. 
Case 1:22-cr-00330-JKB     Document 23     Filed 09/13/23     Page 1 of 1

File and source

File

gov.uscourts.mdd.519685.23.0.pdf

Size

97,730 bytes

SHA-256

22e7a7fee33167bec411eb93ed7a2b81ed998b286c39174b396a0baf83d0f682

Our copy

gov.uscourts.mdd.519685.23.0.pdf

Original

PACER (login required)