Unopposed Motion to Continue trial and to Extend Time to File Pretrial Motions by Caleb Walsh — USA v. Walsh (Dkt. 25, M.D. Fla.)

Record facts

U.S. District Court for the Middle District of Florida · No. 8:26-cr-00083-KKM-LSG · Doc. 25 · 2026-03-24 · Docket on CourtListener

Full text

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UNITED STATES DISTRICT COURT 
MIDDLE DISTRICT OF FLORIDA 
TAMPA DIVISION 
 
UNITED STATES OF AMERICA  
 
 
 
 
 
 
 
 
 
            
vs. 
 
 
 
 
 
        Case No.: 8:26-cr-83-KKM-LSG 
 
 
 
 
 
 
 
 
 
 
CALEB WALSH 
 
Defendant. 
 
 
                                            / 
 
DEFENDANT’S UNOPPOSED MOTION TO CONTINUE TRIAL AND 
TO EXTEND TIME TO FILE PRETRIAL MOTIONS  
 
COMES NOW the defendant, Caleb Walsh, by and through undersigned 
counsel, pursuant to 18 U.S.C. § 3161(h)(7)(B) and Local Rule 3.08, and hereby 
moves this Court to continue the trial currently set for the May 2026 trial term 
for a period of at least six (6) months, and to extend the deadline to file pretrial 
motions by an additional 60 days, and in support thereof states the following: 
1. Defendant was indicted in this matter on March 10, 2026. Doc. 1.  
2. On December March 17, 2026, Defendant filed his Waiver of Presence at 
Arraignment and Entry of Not Guilty Plea. Doc. 15. That same day, the 
Court granted Defendant’s Waiver of Presence at Arraignment (Doc. 15). 
3. On March 20, 2026, the Court entered its Pretrial Discovery Order and 
Notice of Trial and Status Conference (the “Pretrial Order”). Doc. 21. 
4. In the Pretrial Order, the Court set the deadline for pretrial motions as 
within thirty (30) days after receipt of the Government’s discovery. The 
Court also set this case for trial during the May 2026 trial term.  
Case 8:26-cr-00083-KKM-LSG     Document 25     Filed 03/24/26     Page 1 of 4 PageID 75

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5. Defendant is charged with six (6) counts of bank fraud, one (1) count of 
wire fraud, and five (5) counts of money laundering.  
6. Discovery in this matter, which has not yet been received, is expected to 
be voluminous. Counsel for the Government has requested a 3 TB 
(terabyte)1 hard drive to provide the discovery to defense counsel. It is 
expected that, given the charges in this case, the discovery will contain 
volumes of bank and financial records, which will need to be analyzed 
and scheduled. It is also likely that the defense will need to obtain 
additional financial and other records in support of its theory and 
strategy., The defense will be preparing pretrial motions to be heard as 
well as likely asking the Court to issue pretrial subpoenas under Rule 
17, Fed. R. Crim. P. In addition, given the nature of the allegations, there 
are also a number of defense witnesses that need to be identified, located, 
and interviewed.  
7. Considering 18 U.S.C. 3161(h)(7)(B)(ii), the large amount of data renders 
this case unusual and complex, and therefore the parties agree it is 
unreasonable to expect adequate defense preparation for pretrial 
proceedings or for trial by May 2026.  
8. Given the extent of the expected discovery and the necessity of 
 
1 3 TB is equivalent to 3,000 GB (gigabytes) and has the ability to store the equivalent of 300 
million documents, approximately 850,000 photos, or 300 hours of video files. That is to say, 
3 TB is an immense amount of data.  
Case 8:26-cr-00083-KKM-LSG     Document 25     Filed 03/24/26     Page 2 of 4 PageID 76

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conducting a complex defense investigation, undersigned counsel 
requests additional time to review the discovery and file any potential 
pretrial motions. Undersigned further requests the trial be continued for 
at least six (6) months.  
9. Undersigned counsel has conferred with AUSA Christopher Poor, who 
advises that he has no objection to a 60-day extension of the pretrial 
motion deadline, and has no objection to a 6-month continuance of the 
trial term.  
10. Pursuant to the Pretrial Order and Local Rule 3.08, Defendant consents 
to this continuance. Defendant further waives his right to a speedy trial 
through December 31, 2026. 
WHEREFORE, for the reasons stated herein, Defendant respectfully 
requests that this Court grant the requested relief.  
Dated: March 24, 2026  
 
 
Respectfully submitted, 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
/s/ Todd Foster  
 
 
 
 
 
 
 
 
TODD FOSTER 
 
 
 
 
 
 
 
Florida Bar No.: 0325198 
 
 
 
 
 
 
 
tfoster@jpfirm.com 
KEVIN DARKEN 
Florida Bar No.: 90956 
kdarken@jpfirm.com 
MELISSA KWITKO 
 
 
 
 
 
 
 
Florida Bar No.: 1025759 
 
 
 
 
 
 
 
mkwitko@jpfirm.com 
 
 
 
 
 
 
 
JOHNSON POPE BOKOR 
 
 
 
 
 
 
 
RUPPEL & BURNS LLP 
 
 
 
 
 
 
 
400 N. Ashley Drive, Suite 3100 
 
 
 
 
 
 
 
Tampa, FL 33602 
 
 
 
 
 
 
 
Telephone: (813) 225-2500 
 
 
 
 
 
 
 
Attorneys for the Defendant 
Case 8:26-cr-00083-KKM-LSG     Document 25     Filed 03/24/26     Page 3 of 4 PageID 77

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CERTIFICATE OF SERVICE 
 
 
I HEREBY CERTIFY that I filed the foregoing with the Clerk of Court 
for the Middle District of Florida on this 24th day of March 2026 by uploading 
it to the CM/ECF system, which will send a notice of electronic filing to all 
counsel of record. 
 
 
 
 
 
 
/s/ Todd Foster  
 
 
 
 
 
 
 
 
TODD FOSTER 
 
Case 8:26-cr-00083-KKM-LSG     Document 25     Filed 03/24/26     Page 4 of 4 PageID 78

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