Assented Motion to Continue Preliminary Hearing — USA v. Staveley (Dkt. 26, D.R.I. No. 1:20-mj-00034, docketed in No. 1:20-cr-00074)

Summary

Defendant David Adler Staveley files an Unopposed Motion to Continue the Preliminary Hearing scheduled for August 26, 2020. The motion states that his current lead counsel has not determined whether he is able to represent Mr. Staveley going forward and expects to make a final decision this week, or at the latest by Monday, August 31. It states that the Government's attorney informed counsel that the Government does not object. Mr. Staveley requests a continuance of approximately twenty (20) days. The signature line reads /s/ Mark L. Josephs, dated August 25, 2020.

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IN THE UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF RHODE ISLAND 
  
UNITED STATES OF AMERICA  
 
: 
 
 
 
 
 
 
 
: 
 
 
 
v. 
 
 
 
 
: 
No. 1:20-mj-00034-LDA 
 
 
 
 
 
 
 
 
: 
DAVID ADLER STAVELEY 
 
 
: 
 
 
 
 
 
 
 
  
 
 
DEFENDANT’S UNOPPOSED MOTION TO CONTINUE PRELIMINARY HEARING 
 
 
 Defendant David Adler Staveley respectfully submits this Unopposed Motion to 
Continue the Preliminary Hearing currently scheduled for August 26, 2020.  Mr. Staveley seeks 
this continuance because his current lead counsel has not determined whether he is able to 
represent Mr. Staveley going forward, but counsel expects to make a final decision this week.  
For this reason, counsel has not met with Mr. Staveley regarding the Preliminary Hearing, nor 
has he prepared for it.  The Government’s attorney informed undersigned counsel that the 
Government does not object to this Motion. 
 
Undersigned counsel represented Mr. Staveley intermittently in the past and had agreed 
to represent him when Mr. Staveley became aware of the charges in this matter.  As the Court is 
aware, unusual circumstances ensued over the past three months, and counsel for a period of 
time did not believe that his representation would be necessary.  After Mr. Staveley was arrested 
in Georgia, counsel communicated with Mr. Staveley’s family, and it became unlikely that 
counsel would be compensated for representation now or in the future.  That circumstance 
recently changed, however, and counsel is reconsidering whether he will continue to represent 
Mr. Staveley in this proceeding.  Counsel should make a final decision by the end of this week or 
at the latest by Monday, August 31.   
Case 1:20-cr-00074-WES-LDA     Document 26     Filed 08/25/20     Page 1 of 3 PageID #:
105

 
2 
 
Mr. Staveley accordingly requests a continuance of approximately twenty (20) days for 
the preliminary hearing and respectfully requests that this Motion be granted. 
 
 
 
 
 
 
 
 
 
Respectfully submitted, 
David Adler Staveley 
 
 
By his attorney, 
 
Dated:  August 25, 2020 
 
 
 
 
/s/ Mark L. Josephs 
 
 
 
 
 
 
 
 
 
Mark L. Josephs 
 
 
 
 
 
 
 
 
Bar No. 568454 
 
 
 
 
 
 
 
 
Law Office of Mark L. Josephs LLC 
 
 
 
 
 
 
 
 
100 Cambridge Street, 14th Floor 
 
 
 
 
 
 
 
 
Boston, MA  02114 
 
 
 
 
 
 
 
 
(202) 904-4736 
 
 
 
 
 
 
 
 
mark.josephs@markljosephslaw.com 
 
 
 
Case 1:20-cr-00074-WES-LDA     Document 26     Filed 08/25/20     Page 2 of 3 PageID #:
106

 
3 
 
 
 CERTIFICATE OF SERVICE 
 
I hereby certify that this document filed through the ECF system will be sent 
electronically to the registered participants as identified on the Notice of Electronic Filing (NEF), 
and paper copies will be sent to anyone indicated as a non-registered participant on August 25, 
2020. 
 
 
 
 
 
 
 
 
/s/ Mark L. Josephs 
 
 
 
 
 
Mark L. Josephs 
 
 
 
 
 
Case 1:20-cr-00074-WES-LDA     Document 26     Filed 08/25/20     Page 3 of 3 PageID #:
107

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