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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“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/
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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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