Court filing — No. 6:25-mj-01031 (Dkt. 11, M.D. Fla.)
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Case 6:25-mj-01031-RMN Document11_ Filed 02/03/25 Page 1 of 3 PagelD 39 UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA ORLANDO DIVISION UNITED STATES OF AMERICA v. CASE NO. 6:25-mj-01031-RMN CAROLINA AMESTY JOINT MOTION FOR EXTENSION OF TIME BY WHICH INDICTMENT/INFORMATION MUST BE FILED The parties, through their undersigned counsel, move this Court for an Order extending the time for the return of an indictment or information pursuant to 18 U.S.C. § 3161(b) through and including April 21, 2025. The parties believe that this extension would best serve the interests of justice and that the time would be excludable under 18 U.S.C. § 3161(h)(7)(A). On January 16, 2025, the defendant was charged by criminal complaint for violations of 18 U.S.C. § 641 (theft of government property). Doc. 1. On January 21, 2025, the defendant was served with a summons in connection with the charges. Doc. 6. On January 30, 2025, the defendant executed a waiver of the speedy indictment or information period. See Exhibit 1. Counsel for the United States and the defendant currently are engaged in active discussions regarding the appropriate disposition of this matter and believe that a continuance would serve the ends of justice by providing the parties with reasonable time for such discussions, for adequate preparation for pretrial proceedings, and for effective preparation, taking into account the exercise of Case 6:25-mj-01031-RMN Document11_ Filed 02/03/25 Page 2 of 3 PagelD 40 diligence. Based upon this information, the interests of justice would be served by the parties continuing to attempt to resolve this matter prior to grand jury presentment, indictment, and/or trial. The defendant has been apprised of the constraints of 18 U.S.C. § 3161 et. seg. as it relates to her case and voluntarily and with full knowledge of the consequences hereby waives any time from tolling on her right to a speedy indictment or trial through April 21, 2025. For these reasons, the parties request that the Court grant this Motion and extend the time within which an indictment or information may be filed in this case through April 21, 2025. Ifthe Court grants this Motion, the parties request that the Court find in its Order that the ends of justice served by taking such action outweigh the best interests of the public and the defendant in a speedy indictment and trial, to provide the parties with an opportunity to engage in discussions regarding the disposition of the matter, and to provide the parties with reasonable time for adequate preparation for pretrial proceedings and for effective preparation, taking into account the exercise of diligence. Case 6:25-mj-01031-RMN Document 11 Filed 02/03/25 Page 3 of 3 PagelD 41 Subject to the outcome of the parties’ discussions, the government will file an indictment or information with the Court on or before that date. Bradley Bondi, £6 ‘ Counsel for Carolina Amesty Florida Bar No. 162396 Paul Hastings LLP 2050 M St NW Washington, DC 20036 Telephone: (202) 551-1701 Facsimile: (212) 318-6601 Email: bradbondi@paulhastings.com Respectfully submitted, ROGER B. HANDBERG United States Attorney By: /s/ Sarah Megan Testerman Sarah Megan Testerman Assistant United States Attorney Florida Bar No. 0124884 400 W. Washington St., Suite 3100 Orlando, Florida 32801 Telephone: (407) 648-7500 Facsimile: (407) 648-7643 Email: megan.testerman@usdoj.gov
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