Second Consent Motion to Continue Preliminary Hearing and Waive Filing of Indictment — United States v. Bryant (D. Md.)

Summary

Second Consent Motion to Continue Preliminary Hearing and Waive Filing of Indictment, filed January 12, 2022 as Document 25, Case 8:22-cr-00308-DLB, United States v. Sherrie Lynne Bryant, District of Maryland. The Government states that Defendant was charged by Criminal Complaint on August 24, 2021 with wire fraud (18 U.S.C. § 1343) and false statements (18 U.S.C. § 1001). It asks the Court to continue the Preliminary Hearing and the indictment deadline until February 12, 2022, stating that Defendant, through counsel, agrees and that the parties are engaged in plea negotiations. The motion is signed /s/ Rajeev R. Raghavan, Assistant United States Attorney.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Full text

            Case 8:22-cr-00308-DLB Document 25 Filed 01/12/22 Page 1 of 3



                          IN THE UNITED STATES DISTRICT COURT
                             FOR THE DISTRICT OF MARYLAND

 UNITED STATES OF AMERICA                         *
                                                  *
            v.                                    * CASE NO. GLS-21-2249
                                                  *
 SHERRIE LYNNE BRYANT,                            *
                                                  *
            Defendant                             *
                                                  *
                                               *******

                    SECOND CONSENT MOTION TO CONTINUE
            PRELIMINARY HEARING AND WAIVE FILING OF INDICTMENT

       The United States of America, by and through the undersigned attorney, hereby requests an

order continuing the Preliminary Hearing and the deadline for filing an indictment in this matter until

February 12, 2022. In support of this motion, the Government states as follows:

       1.        On August 24, 2021, Defendant was charged by Criminal Complaint with wire fraud,

in violation of 18 U.S.C. § 1343; and false statements, in violation of 18 U.S.C. § 1001.

       2.        On August 25, 2021, an Initial Appearance was held before the Honorable Magistrate

Judge Gina L. Simms. The Defendant was ordered released on conditions and a preliminary hearing

was scheduled for September 15, 2021.

       3.        Pursuant to Fed. R. Crim. P. 5.1(c), a preliminary hearing must be held no later than

14 days after the initial appearance if the Defendant is in custody, or no later than 21 days if the

Defendant is not in custody.

       4.        Pursuant to the Speedy Trial Act, the Government must file an indictment or

information resulting from the charge against Defendant within thirty days of her arrest. See 18

U.S.C. § 3161(b).
              Case 8:22-cr-00308-DLB Document 25 Filed 01/12/22 Page 2 of 3



         5.      Federal Rule of Criminal Procedure 5.1(d) provides, “With the defendant’s consent

and upon a showing of good cause—taking into account the public interest in the prompt disposition

of criminal cases—a magistrate judge may extend the time limits in Rule 5.1(c) one or more times.

. . .”

         6.      The Government and counsel for the Defendant have discussed the preliminary

hearing and Speedy Trial deadlines. The Defendant, through counsel, agrees that the time within

which a preliminary hearing must be held or an indictment filed may be extended to and including

February 12, 2022.

         7.      The Government submits that there is good cause to extend the time in which it must

file an indictment or the Court must hold a preliminary hearing.          Discovery in this case is

voluminous and the requested extension would allow the Defendant an opportunity to review and

discuss the discovery with counsel. The parties are also engaged in plea negotiations and therefore

an extension will provide the parties the opportunity to discuss a possible resolution of this case in

lieu of trial, which would serve the public interest in prompt disposition of criminal cases. See Fed.

R. Crim. P. 5.1(d); 18 U.S.C. § 3161(h)(7).

         8.      A proposed order is submitted herewith.




                                                  2
           Case 8:22-cr-00308-DLB Document 25 Filed 01/12/22 Page 3 of 3



       Based on the foregoing, the Government respectfully requests that the Court grant this

Motion and continue the Preliminary Hearing in this matter and the deadline for filing an indictment

until February 12, 2022.



                                              Respectfully submitted,

                                              Erek L. Barron
                                              United States Attorney


                                        By:      /s/
                                              Rajeev R. Raghavan
                                              Assistant United States Attorney




                                                  3


File and source

File

25.pdf

Size

155,866 bytes

SHA-256

c227a33873c1b557dec3c689558678a272036e0a8a23ca6f7da7dddacef707a5

Our copy

25.pdf

Original

No public link identified.