First Motion for Speedy Trial by USA — USA v. Keough (Dkt. 15, S.D. Fla. No. 9:23-mj-08393, docketed in No. 9:23-cr-80154)

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An Unopposed Motion for Extension of Time to Indict, entered on the docket August 21, 2023 as Doc. 15 in United States of America v. Gregory Scott Keough, Case No. 23-MJ-8393-WM, in the U.S. District Court for the Southern District of Florida (No. 9:23-cr-80154-DMM). The United States and Gregory Scott Keough, through counsel, move under the Speedy Trial Act, 18 U.S.C. § 3161(h)(7), to exclude the time from August 23, 2023 to August 25, 2023 and extend the date by which the matter must be indicted. The stated grounds are that the parties wish to have additional time for discussion about pre-trial detention and/or bond or an alternate resolution. The motion states that David Joffe, counsel to the defendant, does not object, and it is signed /s/ Robin W. Waugh.

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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
 
CASE NO.  23-MJ-8393-WM 
 
UNITED STATES OF AMERICA 
 
vs. 
 
GREGORY SCOTT KEOUGH, 
 
 
 
 
Defendant. 
__________________________________________/ 
UNOPPOSED MOTION FOR EXTENSION OF TIME TO INDICT 
 
The United States of America and Gregory Scott Keough, through their respective 
undersigned counsel, hereby move the Court to enter an order under the Speedy Trial Act, 18 
U.S.C. § 3161(h)(7), excluding the time that elapses from August 23, 2023 to August 25, 2023, 
from calculation of the deadlines set forth in the Act and extending the date by which this matter 
must be indicted. In support of this motion, the parties state the following: 
The extension of time to indictment from August 23, 2023 to August 25, 2023, is filed on 
the grounds that the parties wish to have an additional period of time in which to engage in pre-
trial discussion relating to pre-trial detention and/or bond or an alternate resolution to this case. 
The defendant, through counsel, waives his right to a speedy indictment and agrees that the 
time from August 23, 2023 to August 25, 2023, should be excluded under the Speedy Trial Act, 
18 U.S.C. § 3161(h)(7), from calculation of the deadlines set forth in the Act, and waives his rights 
under the Act for that requested period of exclusion. The interest of justice to be served by the 
requested exclusion of time outweigh the interest of the defendant and the public in a speedy trial 
because the charges herein are very serious and the potential to resolve the case by agreement 
would promote a speedy and certain outcome of the case.  
Case 9:23-cr-80154-DMM   Document 15   Entered on FLSD Docket 08/21/2023   Page 1 of 3

The undersigned Assistant United States Attorney has conferred with David Joffe, counsel 
to Defendant Gregory Scott Keough, who does not object to this filing. 
WHEREFORE, the parties respectfully request that the Court enter an Order excluding the 
period of time from August 23, 2023 to August 25, 2023, should be excluded from calculation 
under the provisions of the Speedy Trial Act.  
    
 
Respectfully submitted, 
 
 
MARKENZY LAPOINTE 
 
UNITED STATES ATTORNEY 
 
 
 
 
 
 
 
/s/ Robin W. Waugh             
 
 
 
 
 
 
ROBIN W. WAUGH 
 
 
 
 
 
 
 
Assistant United States Attorney 
 
Florida Bar #: 537837 
 
500 South Australian Avenue, 4th Flr. 
 
West Palm Beach, Florida 33401 
 
 
 
 
 
 
 
Tel: (561) 820-8711 
 
 
 
 
 
 
 
Fax: (561) 659-4526 
 
 
 
 
 
 
 
Robin.waugh@usdoj.gov 
 
 
 
 
Case 9:23-cr-80154-DMM   Document 15   Entered on FLSD Docket 08/21/2023   Page 2 of 3

CERTIFICATE OF SERVICE 
I hereby certify that on August 21, 2023, the undersigned electronically filed the foregoing 
document with the Clerk of the Court using CM/ECF.   
/s/ Robin W. Waugh                   
 
ROBIN W. WAUGH 
Assistant United States Attorney 
 
Case 9:23-cr-80154-DMM   Document 15   Entered on FLSD Docket 08/21/2023   Page 3 of 3

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