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Case 6:25-mj-01031-RMN Document 25 Filed 07/11/25 Page 1 of 6 PageID 95
UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
ORLANDO DIVISION
UNITED STATES OF AMERICA
v. CASE NO. 6:25-mj-1031-RMN
CAROLINA AMESTY
UNITED STATES’ TIME-SENSITIVE
RENEWED MOTION FOR EXTENSION OF TIME
BY WHICH INDICTMENT/INFORMATION MUST BE FILED
The government files this renewed 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 government believes 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). The government also includes in this motion the detailed
factual proffer that the Court has required for any further extensions of this deadline.
See Doc. 24 at 3.
In compliance with Local Rule 3.01(e), the government requests a ruling on
this motion by Tuesday, July 15, 2025, due to the deadline in the Court’s Order
dated June 20, 2025 (Doc. 24).
BACKGROUND
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
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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
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, through August 22, 2025. Doc. 23-1. In
connection with that waiver, the parties filed a third joint motion for an extension of
time by which an indictment or information must be filed. Doc. 23. The Court
partially granted that motion, granting an extension through July 23, 2025, and
finding that the additional time was excludable under 18 U.S.C. § 3161(h)(7). Doc.
24. The Court determined, though, that any further extension was not warranted
based on the information before it and stated that a detailed factual proffer would be
necessary if they sought any further continuances. Id.
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DISCUSSION
As the parties have previously stated to the Court, counsel for the United
States and the defendant currently are engaged in active discussions regarding the
appropriate disposition of this matter. To provide more detail on these discussions,
current counsel for Amesty were retained around December 13, 2024. Over the
following months and through the present, counsel have provided extensive
information to the United States that they believe is exculpatory to their client. This
includes dozens of pages of summaries and letters, multiple in-person meetings and
phone calls, and over 500 pages of documents. Over 100 pages of documents were
produced on June 13, 2025, along with a 22-page summary letter. 1 The United States
has undertaken a diligent and expeditious review of these recent defense disclosures
but needs additional time to carry out its obligations to fully review and consider
these materials in its decision on how to proceed. In addition to the United States’
obligation to fully review and consider these materials, the defendant has stated in
correspondence and in discussions with the United States that it is incumbent upon
the United States to fully review these materials prior to making a final decision as to
the disposition of this matter.
Additionally, the United States’ investigation remains ongoing, due in part to
a pending sealed motion related to grand jury proceedings. See Exhibit 1. The results
Since December 2024, the United States has also provided multiple summary letters and
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many documents to the defendant as part of the ongoing discussions between the parties.
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of this ongoing investigation are relevant to the United States’ assessment of the
appropriate disposition of this matter and thus to the parties’ ongoing discussions.
CONCLUSION
For these reasons, the government renews its request to this Court for an
extension of the deadline to indict and believes that a continuance would serve the
ends of justice by providing the United States with reasonable time for full
consideration of the materials provided by Amesty and providing the parties with
reasonable time for additional discussions, 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. Should the Court require further detail regarding the
matters discussed above, the government requests a hearing to supplement the
record.
As stated in the parties’ joint motion for extension dated June 15, 2025 (Doc.
23 at 2), 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, previously waived any time from tolling on her right to a speedy
indictment or trial through August 22, 2025.
The government respectfully requests 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 government also
requests that the Court find in its Order that the ends of justice served by taking such
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action outweigh the best interests of the public and the defendant in a speedy
indictment and trial.
Moreover, if the Court grants this Motion, the government will make a final
decision as to the appropriate disposition of this case on or before August 22, 2025.
Local Rule 3.01(g) Certification. In compliance with Local Rule 3.01(g), on
July 10, 2025 and July 11, 2025, the government conferred via email with defense
counsel regarding this motion. Additionally, on July 11, 2025, the government called
defense counsel following up regarding defense counsel’s position. As of the time of
filing of this motion, defense counsel have not provided the government with their
position on this motion, though the United States understands that defense counsel
are aware of and considering the motion.
Respectfully submitted,
GREGORY W. KEHOE
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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U.S. v. CAROLINA AMESTY Case No. 6:25-mj-1031-RMN
CERTIFICATE OF SERVICE
I hereby certify that on July 11, 2025, I electronically filed the foregoing with
the Clerk of the Court by using the CM/ECF system which will send a notice of
electronic filing to the following:
Bradley Bondi
Attorney for Defendant
By: /s/ Sarah Megan Testerman
Sarah Megan Testerman
Assistant United States Attorney
Florida Bar No. 0124884
400 W. Washington Street, Suite 3100
Orlando, Florida 32801
Telephone: (407) 648-7500
Facsimile: (407) 648-7643
E-mail: megan.testerman@usdoj.gov
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