Joint Motion for Continuance — United States v. Ross Sylvester Elendu (D.N.D., Dkt. 20, filed 10/08/24)

Summary

A Joint Motion for Continuance filed October 8, 2024 as Document 20 in United States v. Ross Sylvester Elendu, Case No. 3:24-CR-00142 (3:24-cr-00142-PDW), in the U.S. District Court for the District of North Dakota. The United States and the defendant, through counsel Rhi Gorham, move under 18 U.S.C. § 3161(h)(7)(A) to continue the jury trial set for October 22, 2024 for at least 60 days so the parties can satisfy discovery obligations and prepare for trial. The motion states there are approximately 8000 Bates stamped pages of discovery, that the United States will seek a protective order to disclose additional tax records, and that the defendant's written consent is attached. The signature block of Matthew D. Greenley appears with /s, dated October 7, 2024.

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UNITED STATES OF AMERICA,

ROSS SYLVESTER ELENDU,

Case 3:24-cr-00142-PDW Document 20 Filed 10/08/24 Page 1 of 2

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF NORTH DAKOTA

Case No. 3:24-CR-00142
Plaintiff,
JOINT MOTION FOR
V. CONTINUANCE

Defendant.

The United States of America, by Mac Schneider, United States Attorney for the

District of North Dakota, and Matthew D. Greenley, Assistant United States Attorney,

Defendant, ROSS SYLVESTER ELENDU; and Defendant’s counsel, Rhi Gorham,

jointly move the Court under 18 U.S.C. § 3161(h)(7)(A) to continue the jury trial in the

above captioned matter, currently set for October 22, 2024, for a period of at least 60

days to permit the parties to satisfy discovery obligations and prepare for trial.

1,

2.

The Defendant is currently on release based on the stipulation of the parties.

To date, there are approximately 8000 Bates stamped pages of discovery, and the
United States intends to disclose additional discovery.

. The United States will seek a protective order to disclose additional certain tax

records to the Defendant.

The parties have been diligent in preparation for trial and jointly seek a
continuance to further prepare for trial.

. The parties agree that the ends of justice served by granting this continuance will

outweigh the bests interests of the public and the defendant in a speedy trial.

The Defendant’s written consent to a continuance is attached to this motion.
Case 3:24-cr-00142-PDW Document 20 Filed 10/08/24 Page 2 of 2

MAC SCHNEIDER
United States Attorney

Dated: October 7, 2024 By: /s Matthew D. Greenley
MATTHEW D. GREENLEY
Assistant United States Atto ey

Dated: ofa {a4 a Th

‘RHI GORHAM


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