Court filing

Paed.569219.26.0 - Us V Williams Cisco

One of 3 filings in U.S. v. Williams Cisco.

What This Document Is

A 3-page unopposed defense motion filed May 14, 2021 by Williams's retained counsel Troy A. Archie, asking the court to continue the trial then scheduled for June 4, 2021 to a date not earlier than December 1, 2021. Pages 2-3 are the certificate of service and an unexecuted proposed order (blank date, trial-date, and signature lines — a proposal, not a ruling).

Factual Summary

The motion states that Williams was arraigned on the superseding indictment before Magistrate Judge Lynne A. Sitarski on October 23, 2020 and pleaded not guilty. Counsel gives two grounds for the continuance: first, the defense has requested and received 49,000 pages of discovery in a case designated as complex, and needs more time to review the materials, consult Williams, investigate, and determine whether a non-trial disposition is possible; second, Williams has been caring for his son, who recently began radiation treatment for malignant soft tissue sarcoma expected to extend into the fall of 2021. AUSA Michael Lowe did not oppose the motion, and defense counsel stipulated that the time through the new trial date is excludable under the Speedy Trial Act, 18 U.S.C. § 3161(h)(7).

Key Facts

Filed May 14, 2021 by retained counsel Troy A. Archie; unopposed by the government.
Requests continuance of the June 4, 2021 trial date to no earlier than December 1, 2021.
Discloses 49,000 pages of produced discovery and the case's complex designation — the figure the court's later pretrial-motions opinion (Doc. 30) also cites.
States Williams's son had recently begun radiation treatment for malignant soft tissue sarcoma.
Includes a Speedy Trial Act excludable-time stipulation under 18 U.S.C. § 3161(h)(7).
The attached order is an unexecuted proposal; the granting order is a separate docket entry (the withdrawal order at Doc. 33 notes the parties "recently consented to a continuance" and that trial moved to January 2022, citing ECF 27, which is not in this folder).

Source Caveats

The order at pages 2-3 is an unexecuted proposed order (blank date and signature lines); nothing in this document itself grants the continuance. The granting order (referenced elsewhere as ECF 27) is not in this folder.
The son's-illness representation is defense counsel's unsworn statement in a motion, unopposed but not adjudicated.
No canonical source page exists for this document; none has been fabricated (this document was not part of the original site registry — see the case-level SUMMARY.md registry-gap note).

No. 2:20-cr-00143-JMG · Doc. 26 · Docket on CourtListener

Full text

Case 2:20-cr-00143-JMG Document 26 Filed 05/14/21 Page 1 of 3

UNITED STATES DISTICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA

UNITED STATES OF AMERICA, :
: CRIMINAL NO.: 20-143
Plaintiff, :
:
vs. : HONORABLE JOHN M. GALLAGHER
:
:
JEREL ANDRE WILLIAMS, :
:
Defendant. :

DEFENDANT’S UNOPPOSED MOTION FOR CONTINUANCE OF TRIAL DATE

Jerel Andre Williams, by his counsel undersigned, respectfully requests that the Court
continue the trial. In support of this request, it is stated:

1. On October 23, 2020, Mr. Williams was arraigned before The Honorable Lynne A. Sitarski,
Magistrate Judge and entered a plea of not guilty to the instant superseding indictment.

2. The trial is scheduled to begin on June 4, 2021.

3. The defense has requested and received 49,000 pages of discovery and the case has been
designated as complex. The defense needs additional time to review the discovery materials,
speak with Mr. Williams, conduct any necessary investigations, determine if a non-trial
disposition is possible or prepare for trial.

4. Additionally, Mr. Williams has been caring for his son who has recently begun radiations
for malignant soft tissue sarcoma and whose treatment will extend into the fall.

5. A continuance until not less than December 1, 2021 is respectfully requested.

6. Assistant United States Attorney Michael Lowe has no objection to this continuance
motion.

7. Defense counsel stipulates that the time from the filing of this motion until the trial date is
excludable time pursuant to 18 U.S.C.§ 3161(h)(7).

Dated May 14, 2021 Respectfully Submitted,

/s/ Troy A. Archie, Esquire
archie@aafnjlaw.com
Counsel for Jerel Andre Williams
Case 2:20-cr-00143-JMG Document 26 Filed 05/14/21 Page 2 of 3

UNITED STATES DISTICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA

UNITED STATES OF AMERICA, :
: CRIMINAL NO.: 20-143
Plaintiff, :
:
vs. : HONORABLE JOHN M. GALLAGHER
:
:
JEREL ANDRE WILLIAMS, : CERTIFICATE OF SERVICE
:
:
:
Defendant. :

CERTIFICATE OF SERVICE

I, Troy A. Archie, Esquire., hereby certify that this Motion for a Continuance was served
Pacer/ECF and via electronic mail Michael Lowe, A.U.S.A. (via
email/mike.lowe@usdoj.gov).

Dated: May 14, 2021 __/s/ Troy A. Archie
TROY A. ARCHIE, ESQUIRE
Case 2:20-cr-00143-JMG Document 26 Filed 05/14/21 Page 3 of 3

IN THE UNITED STATES DISTICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA

UNITED STATES OF AMERICA :
Plaintiff :
v. :
: CRIMINAL NO. 20-143 (JMG)
:
JEREL ANDRE WILLIAMS :
Defendant :

O R D E R AND NOW, this ______ day of , _______________ 2021, upon consideration of

the Defendant’s Unopposed Motion for Continuance of Trial Date, it is hereby ORDERED

that the motion is GRANTED. The Court finds that the defense need additional time to

obtain and review discovery as well as defendant having a family medical issue. Pursuant to

18 U.S.C. § 3161(h)(7), the Court finds that the ends of justice served by the continuance

outweigh the best interest of the public and the defendant in a speedy trial. Trial in this matter

shall begin on the ____________ day of, _______________ 20__

BY THE COURT:

_______________________
Hon. John M. Gallagher
United States District Court

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