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Letter to Judge Berman — United States v. Muge Ma (Southern District of New York, Document 39)

Summary

A letter dated April 28, 2021, to Judge Richard M. Berman in United States v. Muge Ma, 20 CR 407 (RMB), from Peter Katz, counsel to Mr. Ma. It asks that the telephonic status conference scheduled for May 3, 2021 be adjourned to the week of May 17th or May 24th and converted into a guilty plea colloquy. The letter says the government provided a finalized plea agreement and the parties agree on material terms, but communicating with Mr. Ma during the COVID pandemic and his difficulty using the law library mean they will not be prepared on May 3rd. It requests exclusion of time under the Speedy Trial Act and says Assistant U.S. Attorney Sagar Ravi consents.

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Cite this document

“Letter to Judge Berman — United States v. Muge Ma (Southern District of New York, Document 39).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-s-d-n-y-no-1-20-cr-00407-dkt-39-s-d-n-y-0384b7755d/, SHA-256 b69e5a025cf4a919640f60982cc57cf301afee45d616ddb026d60015d95cff16.

Full text

         Case 1:20-cr-00407-RMB Document 39 Filed 04/28/21 Page 1 of 1




                                                                     April 28, 2021
BY EMAIL
Hon. Richard M. Berman
United State District Judge
Southern District of New York
500 Pearl Street
New York, New York 10007

               Re: United States v. Muge Ma, 20 CR 407 (RMB)

Dear Judge Berman:

         I am counsel to Mr. Ma in the above referenced case. I submit this letter on behalf of
Mr.Ma to request an adjournment of the telephonic status conference scheduled for May 3, 2021
until later in May 2021 and to convert that conference into a guilty plea colloquy.

        The government has provided me with a finalized version of the plea agreement, which I
have mailed to Mr. Ma. We are in agreement on the material terms, however, because of the
difficulty communicating with Mr. Ma due to the COVID pandemic as well as his difficulty using
the law library, we will not be prepared to plead on May 3rd. Accordingly, in order to allow time
for us to adequately prepare for the plea, we respectfully request that the May 3, 2021 conference
be adjourned until the week of May 17th or May 24th.

        We respectfully request and consent that time be excluded under the Speedy Trial Act until
the next conference date set by the Court pursuant to Title 18, United States Code, Section
3161(h)(7)(A). The exclusion of time best serves the ends of justice and outweighs the best
interests of the public and the defendant in a speedy trial as it will allow time for the parties to
continue our on-going discussions regarding a potential disposition of this matter. I have consulted
with Assistant U.S. Attorney Sagar Ravi who consents to this adjournment request and to the
exclusion of time on behalf of the government.

       Thank you for your attention to this matter.

                                                             Sincerely,



                                                             Peter Katz, Esq.
                                                             Counsel to Muge Ma




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