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Motion to Continue and to Exclude Period of Continuance from the Speedy Trial Act (Abdirahman Mohamud Ahmed) — United States v. Bock et al. (Feeding Our Future) (Dkt. 740, D. Minn.)

Summary

Motion to Continue and to Exclude Period of Continuance from the Speedy Trial Act, filed July 23, 2025 as Doc. 740 in United States of America v. Abdirahman Mohamud Ahmed, Criminal No. 22-cr-223 (NEB/DTS), U.S. District Court for the District of Minnesota. Abdirahman Ahmed, through counsel, asks to continue his trial and all attendant deadlines and to exclude the period of the continuance from the Speedy Trial Act clock under 18 U.S.C. § 3161. The motion states that Mr. Ahmed received new trial counsel on July 11, 2025, that trial counsel needs a minimum of three months to prepare, and that the government did not object to the extension request or amount. It also states that a proposed, draft order is offered under separate cover. The signature block names Dane DeKrey of Ringstrom DeKrey PLLP.

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Cite this document

“Motion to Continue and to Exclude Period of Continuance from the Speedy Trial Act (Abdirahman Mohamud Ahmed) — United States v. Bock et al. (Feeding Our Future) (Dkt. 740, D. Minn.).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-united-states-v-bock-et-al-feeding-our-future-dkt-740-d-m-70f13096fc/, SHA-256 e46774c24d6e84b1c55536e22ffef69489ece01ca658b7e56e4e0a482f567758.

Full text

       CASE 0:22-cr-00223-NEB-DTS        Doc. 740    Filed 07/23/25   Page 1 of 2



                       UNITED STATES DISTRICT COURT
                          DISTRICT OF MINNESOTA
                        Criminal No. 22-cr-223 (NEB/DTS)

 United States of America,

                          Plaintiff,
                                             MOTION TO CONTINUE AND
 vs.                                           TO EXCLUDE PERIOD OF
                                              CONTINUANCE FROM THE
 Abdirahman Mohamud Ahmed,                       SPEEDY TRIAL ACT

                          Defendant.


       Abdirahman Ahmed, through counsel, respectfully offers the following motion

to continue his trial and all attendant deadlines and motions in his case, and to exclude

the period of this continuance from the Speedy Trial Act clock. For the reasons

outlined below, Mr. Ahmed seeks a three-month extension of the proceedings. This

extension was discussed with the government, and the government stated that it did

not object to either the extension request or amount.

       The defense therefore respectfully requests additional time given that Mr.

Ahmed received new trial counsel on July 11, 2025. Given the size and scope of the

case, trial counsel needs a minimum of three months to prepare the case for all pretrial

and trial matters. At the end of the three months, trial counsel will confer with the

government to discuss whether more time is needed for trial preparation or if the case

is ready to proceed to trial.
       CASE 0:22-cr-00223-NEB-DTS        Doc. 740    Filed 07/23/25   Page 2 of 2



      Accordingly, the facts outlined in the statement above support a suspension of

proceedings, in light of which the requested extension is in the interest of justice, and

as such is supported by the Speedy Trial Act, 18 U.S.C. § 3161, et seq. Counsel has

discussed the Speedy Trial Act and its application to this case with Mr. Ahmed, who

understands and supports the requested extension.

      The defense therefore respectfully moves for: (1) a three-month continuance of

the schedule and deadlines for pretrial motions proceedings that have been set in this

case; and (2) for a determination that the period of delay occasioned by this

continuance should be excluded from the speedy trial computation on the ground that

the interest of justice served by granting the requested continuance outweighs the

interest of the public and the defendant in a speedy trial. A proposed, draft order is

offered under separate cover.


Date: July 23, 2025                     Respectfully submitted,




                                        Dane DeKrey (#0397334)
                                        RINGSTROM DEKREY PLLP
                                        814 Center Avenue, Suite 5
                                        Moorhead, MN 56560
                                        (218) 284-0484
                                        dane@ringstromdekrey.com




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