Time-Sensitive Joint Motion for Extension of Time — United States v. Carolina Amesty (M.D. Fla.)
Summary
A Time-Sensitive Joint Motion for Extension of Time by Which Indictment/Information Must be Filed, Document 21, filed 04/15/25, Case 6:25-mj-01031-RMN, United States of America v. Carolina Amesty, Middle District of Florida, Orlando Division. The parties ask the Court to extend the time for the return of an indictment or information under 18 U.S.C. § 3161(b) through and including June 20, 2025, and request a ruling by Friday, April 18, 2025, because the current deadline is Monday, April 21, 2025. The motion recounts the January 16, 2025, complaint under 18 U.S.C. § 641 and states that on April 15, 2025, the defendant executed a second waiver of the speedy indictment period. Signed by counsel for the defendant and an Assistant United States Attorney.
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“Time-Sensitive Joint Motion for Extension of Time — United States v. Carolina Amesty (M.D. Fla.).”
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Case 6:25-mj-01031-RMN Document 21 Filed 04/15/25 Page 1 of 3 PageID 79
UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
ORLANDO DIVISION
UNITED STATES OF AMERICA
v. CASE NO. 6:25-mj-01031-RMN
CAROLINA AMESTY
TIME-SENSITIVE JOINT MOTION FOR EXTENSION OF TIME
BY WHICH INDICTMENT/INFORMATION MUST BE FILED
The parties, through their undersigned counsel, file this time-sensitive motion
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 June 20, 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).
In compliance with Local Rule 3.01(e), the parties request a ruling on this
motion by Friday, April 18, 2025, as the current indictment deadline is Monday,
April 21, 2025. Doc. 12.
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 30,
2025, the defendant executed a waiver of the speedy indictment or information
period. Doc. 11-1. On February 3, 2025, the parties filed a joint motion to extend
time to file an indictment or information, which the Court granted on February 5,
2025. Doc. 11; Doc. 12. The Court found that the time from January 21, 2025,
through April 21, 2025, was tolled under 18 U.S.C. § 3161(b) and (h)(7). Doc. 12.
Case 6:25-mj-01031-RMN Document 21 Filed 04/15/25 Page 2 of 3 PageID 80
The Court further ordered that, “[a]bsent a further order, the United States shall
return the indictment or information in this matter on or before April 21, 2025.” Id.
The initial appearance was held on February 18, 2025. Doc. 13. Then, on
April 15, 2025, the defendant executed a second waiver of the speedy indictment or
information period, though June 20, 2025. 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
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. seq.
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 June 20, 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 June 20, 2025. If the 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
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Case 6:25-mj-01031-RMN Document 21 Filed 04/15/25 Page 3 of 3 PageID 81
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.
Subject to the outcome of the parties’ discussions, the government will file an
indictment or information with the Court on or before that date.
Respectfully submitted,
By: /s/ Bradley Bondi _ GREGORY W. KEHOE
Bradley Bondi, Esq. United States Attorney
Counsel for Carolina Amesty By: /s/ Sarah Megan Testerman
Florida Bar No. 162396 Sarah Megan Testerman
Paul Hastings LLP Assistant United States Attorney
2050 M St NW Florida Bar No. 0124884
Washington, DC 20036 400 W. Washington St., Suite 3100
Telephone: (202) 551-1701 Orlando, Florida 32801
Facsimile: (212) 318-6601 Telephone: (407) 648-7500
Email: bradbondi@paulhastings.com Facsimile: (407) 648-7643
Email: megan.testerman@usdoj.gov
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