Court filing — United States v. Salim Ahmed Said (Dkt. 857, D. Minn.)

Summary

A Motion to Schedule Sentencing, Doc. 857, filed 05/06/26 in Case 0:22-cr-00223-NEB-DTS, United States of America v. Salim Ahmed Said, Criminal No. 22-CR-223-NEB-DTS, in the U.S. District Court for the District of Minnesota. Through counsel, Said asks the Court to schedule his sentencing hearing for a date that lets counsel submit his sentencing position no later than July 31, 2026. The motion states that new counsel Barry Zone was recently admitted pro hac vice, is obtaining Said's extensive case file after a lengthy trial, must confer with his client, and has trial and personal obligations until June 8th, 2026. It states that the government, by AUSA Rebecca Kline, does not object, and is dated May 6, 2026.

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     CASE 0:22-cr-00223-NEB-DTS             Doc. 857       Filed 05/06/26      Page 1 of 2




                     UNITED STATES DISTRICT COURT
                                DISTRICT OF MINNESOTA

                            Criminal No. 22-CR-223-NEB-DTS

UNITED STATES OF AMERICA,                             MOTION TO SCHEDULE
                                                           SENTENCING

                        Plaintiff(s)            Case No:     0:22-cr-00233-NEB-DTS
v.

SALIM AHMED SAID,

                        Defendant(s)

  ____________________________________________________________________________

        Defendant Salim Ahmed Said in the above-named case, through his counsel, hereby

moves The United States District Court for the District of Minnesota for an Order to:


        Schedule his Sentencing Hearing to a date that would permit counsel to

Submit his sentencing position no later than July 31, 2026, with, of course, ample time for the

Government’s response and the Court’s review.


        Mr. Zone makes this request because he has just recently been admitted to this Court

pro hac vice as to this case, and his Notice of Appearance has also just been accepted. He is in the

process of obtaining Mr. Said’s case file, which I understand is quite extensive, as he was convicted

after a lengthy trial. In fact, given the size of the file, Mr. Colich’s office will be required to load

everything onto an external drive and forward it to my office, which will take some time.

        In addition to Mr. Zone’s need to review and analyze the file, he must speak with the

client regarding the issues, considerations, and concerns that must be submitted to the Court in Mr.
   CASE 0:22-cr-00223-NEB-DTS             Doc. 857      Filed 05/06/26     Page 2 of 2




Said’s Sentencing position submission, as well as for his sentencing hearing. The defendant, of

course, does so request and does agree with the instant application.


       As to Mr. Zone’s trial and personal obligations, he is starting a trial next week in New

York State Supreme Court, and he is getting married at the end of the month and will be back to

work on June 8th, 2026.


       The Government by AUSA Rebecca Kline, as stated in her email of April 27, 2026

does not object to this application, given the above.


       Accordingly, we would respectfully request an order, scheduling Mr. Said’s

Sentencing Hearing to a date that would permit Mr. Zone’s submission of his sentencing position as

requested herein.

Dated: May 6, 2026


                                                            Respectfully Submitted,

                                                            s/ Samuel A. Savage
                                                            Samuel A. Savage (#03956380
                                                            SAVAGE WESTRICK, PLLP
                                                            900 AMERICAN BLVD. E., #241
                                                            Ph:(651) 292-9603
                                                            Email:savage@savagewestrick.com

                                                            s/Barry Zone
                                                            Barry Zone (NY # 2558997)
                                                            405 Lexington Avenue, 12 Fl
                                                            New York, New York 10174
                                                            bzone@mosessinger.com


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