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Home Source documents Court filing — No. 6:25-mj-01031 (Dkt. 23, M.D. Fla.)

Court filing — No. 6:25-mj-01031 (Dkt. 23, M.D. Fla.)

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Case 6:25-mj-01031-RMN        Document 23     Filed 06/15/25   Page 1 of 3 PageID 87




                      UNITED STATES DISTRICT COURT
                       MIDDLE DISTRICT OF FLORIDA
                           ORLANDO DIVISION

UNITED STATES OF AMERICA

v.                                            CASE NO. 6:25-mj-1031-RMN

CAROLINA AMESTY

              JOINT MOTION FOR EXTENSION OF TIME
        BY WHICH INDICTMENT/INFORMATION MUST BE FILED

      The parties, through their undersigned counsel, file this 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 August 22, 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 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.

      The defendant’s 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, through June 20, 2025. Doc. 21-1. In connection
Case 6:25-mj-01031-RMN        Document 23      Filed 06/15/25   Page 2 of 3 PageID 88




with that waiver, the parties filed a second joint motion for an extension of time by

which an indictment or information must be filed, which the Court granted on April

17, 2025. Doc. 21; Doc. 22. The Court found that the time from April 21, 2025,

through June 20, 2025, was excludable under 18 U.S.C. § 3161(h)(7).

      On June 3, 2025, the defendant executed a third waiver of the speedy

indictment or information period, though August 22, 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 August 22, 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 August 22, 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

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Case 6:25-mj-01031-RMN        Document 23      Filed 06/15/25   Page 3 of 3 PageID 89




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.

      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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