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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF RHODE ISLAND
UNITED STATES OF AMERICA,
:
Plaintiff
:
:
V.
:
Case Number: 1:20-mj-00034-LDA
:
David Adler Staveley
Defendant
:
MOTION TO ENLARGE THE TIME FOR PRELIMINARY
HEARING AND REVIEW OF PRELIMINARY HOME
DETENTION AND ELECTRONIC MONITORING ORDER
NOW comes the Defendant, David Adler Staveley, and moves that the court enter
an order extending the time for the Preliminary Hearing and Preliminary Home Detention
and Electronic Monitoring Order for an additional week beyond the scheduled hearing on May
26, 2020, subject to the Court’s calendar. The Defendant is in the process of retaining private
counsel and requires additional time to prepare for the hearings remotely with counsel once
retained. Defendant anticipates that process to be resolved by the end of the week, with
counsel entering on Tuesday, May 26, 2020, following the Memorial Day holiday.
Defendant avers that the interest of justice would be served by allowing additional time
for the preliminary hearing. All orders previously entered are requested to remain in effect.
Currently, an additional week is requested. Such continuance should therefore be excludable
for speedy trial calculation. As a consequence of the foregoing request Counsel necessarily
moves to vacate the hearing date for the preliminary hearing.
Respectfully submitted,
Defendant David Adler Staveley
By his attorney,
/s/ George J. West
George J. West, Esq. #3052
One Turks Head Place, Suite 312
Providence, RI 02903-2215
Case 1:20-cr-00074-MSM-LDA Document 16 Filed 05/20/20 Page 1 of 2 PageID #: 83
(401) 861-9042
(401) 861-0330 Fax
Dated: May 20, 2020
CERTIFICATION
I, the undersigned, do hereby certify that on the 20th day of May, 2020, I caused the
within Defendant’s Motion for Extension of Time to be filed on the ECF System and thereby
served via the same upon Lee Vilker, Esq., Assistant U.S. Attorney.
/s/ George J. West
Case 1:20-cr-00074-MSM-LDA Document 16 Filed 05/20/20 Page 2 of 2 PageID #: 84