Joint Motion to Continue Trial by Gregory Scott Keough. Responses due by 11/1/2023 — USA v. Keough (Dkt. 39, S.D. Fla. No. 9:23-mj-08393, docketed in No. 9:23-cr-80154)

Record facts

U.S. District Court for the Southern District of Florida · No. 9:23-cr-80154-DMM · Doc. 39 · 2023-10-18 · Docket on CourtListener

Full text

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
 
CASE NO. 9:23-cr-80154-DMM-1 
 
UNITED STATES OF AMERICA,    
 
 
Plaintiff, 
vs. 
 
GREGORY SCOTT KEOUGH, 
 
 
Defendant. 
_  
 
 
 
 
/  
 
JOINT MOTION TO CONTINUE CALENDAR CALL AND TRIAL 
Counsels for Defendant Gregory Scott Keough (hereinafter “KEOUGH”), and Counsel 
for The United States of America, pursuant to Federal Rules of Criminal Procedure would hereby 
jointly file this Motion to Continue the Calendar Call and the Trial in the above-styled cause and 
would state the following:  
FACTUAL BACKGROUND 
1. On August 24, 2023, the government filed an eleven-count Indictment against 
KEOUGH.   
2. Counsels for the Defendant were retained on August 16, 2023.  
3. The calendar call is scheduled for October 25, 2023, at 10:30 a.m., and the trial is 
scheduled for October 30, 2023, at 9:00 a.m.  
4. Defense counsels received a significant amount of discovery from the United 
States counsel, and additional time is required to read and review it. 
5. Additionally, counsels for KEOUGH and counsel for the Government have been 
engaged in significant plea discussions and counsels believe that plea negotiations 
are continuing. 
Case 9:23-cr-80154-DMM   Document 39   Entered on FLSD Docket 10/18/2023   Page 1 of 4

6. Defense counsels and the United States respectfully request the continuance of the 
calendar call and the trial.
7. Defense counsels have contacted defense counsel for the United States who indicated 
that she joins in this motion to continue the calendar call and the trial.
Dated: October 18, 2023. 
Respectfully submitted, 
JOFFE LAW, P.A. 
Co-Attorney for KEOUGH 
The 110 Tower Building 
110 S.E. 6th Street, Suite 1700 
Ft. Lauderdale, Florida 33301 
Telephone: 
(954) 723-0007 
Facsimile: 
(954) 723-0033 
davidjjoffe@aol.com 
By                                       
DAVID J. JOFFE, ESQUIRE 
FLORIDA BAR NO. 0814164 
LAW OFFICE OF PATRICK R. 
MCKAMEY  
Co-Attorney for KEOUGH 
515 North Flagler Drive 
Suite P300 
West Palm Beach, Florida 
(561) 370-7424
patrick@mckameydefenselaw.com
By_________________________________ 
PATRICK R. MCKAMEY, ESQUIRE 
FLORIDA BAR NO. 103624 
ROBIN W. WAUGH 
Assistant United States Attorney 
500 S Australian Ave Ste 400 
West Palm Beach, FL 33401-6209 
O: 561-820-8711 
Email: Robin.Waugh@usdoj.gov 
By                                           
ROBIN W. WAUGH, ESQUIRE 
FLORIDA BAR NO. :0537837 
David J. Joffe
Patrick R. McKamey
Robin W. Waugh
/s/
/s/
/s/
Case 9:23-cr-80154-DMM   Document 39   Entered on FLSD Docket 10/18/2023   Page 2 of 4

CERTIFICATE OF SERVICE 
 
I HEREBY CERTIFY that on October 18, 2023, I electronically filed the foregoing 
document with the Clerk of the Court using CM/ECF. 
 
Respectfully submitted, 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 DAVID J. JOFFE, ESQUIRE 
 
 
 
 
 
 
 
       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
/s/ David J. Joffe
Case 9:23-cr-80154-DMM   Document 39   Entered on FLSD Docket 10/18/2023   Page 3 of 4

 
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Case 9:23-cr-80154-DMM   Document 39   Entered on FLSD Docket 10/18/2023   Page 4 of 4

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