Joint Motion to Continue Trial — United States v. Edwards (M.D. Fla., Document 307)

Summary

Joint motion by the United States, through Gregory W. Kehoe, United States Attorney for the Middle District of Florida, and defense counsel Andrew Searle and Corey Cohen to continue the trial set for November 17, 2025, to the January 2026 trial term. It states that the indictment alleges a materially false Paycheck Protection Program loan application on behalf of ASLAN International Ministry, Inc. to First Home Bank, and that funds over $8,000,000 were later seized by the United States. It states that on October 14, 2025 the United States offered the defendant a plea agreement, that Andrew Searle has a federal fraud trial beginning the first week of November, and that the Government is still trying to serve trial subpoenas on witnesses, some of whom reside in Canada.

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“Joint Motion to Continue Trial — United States v. Edwards (M.D. Fla., Document 307).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-united-states-v-joshua-edwards-joint-dkt-307-m-d-fla-01467a685e/, SHA-256 97c686caf9b13412b3a8ffb2a288474120d468defc96d4adf17435b8c9b9e932.

Full text

Case 6:22-cr-00201-WWB-LHP Document 307 Filed 10/17/25 Page 1 of 5 PageID 1796

UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
ORLANDO DIVISION

UNITED STATES OF AMERICA

v. CASE NO. 6:22-cr-00201-WWB-LHP

JOSHUA EDWARDS

JOINT MOTION TO CONTINUE TRIAL

The United States of America, by Gregory W. Kehoe, United States

Attorney for the Middle District of Florida, and counsel for the defendant,

Attorneys Andrew Searle and Corey Cohen request, pursuant to Fed. R. Crim. P.

12(b), that this Court continue the trial in this case now set for November 17,

2025, and in support of its motion states as follows:

1. On December 7, 2022, the defendant was charged by grand jury

indictment with one count of conspiracy to commit bank fraud, one count of bank

fraud, one count of making a false statement to a lending institution, and one

count of visa fraud. Doc. 1.

2. The indictment alleges, among other things, that the defendant

submitted a materially false Paycheck Protection Program loan application on

behalf of ASLAN International Ministry, Inc. to First Home Bank. The indictment

further alleges that, as a result of such application, the defendant and his co-

conspirator(s) fraudulently received funds over $8,000,000, which were later

seized by the United States.
Case 6:22-cr-00201-WWB-LHP Document 307 Filed 10/17/25 Page 2 of 5 PageID 1797

3. From the time of the defendant’s initial appearance in December

2022 through March 2025, competency proceedings for the defendant were

ongoing, ultimately resulting in the defendant’s restoration to competency. See

Docs. 9, 14, 70, 72, 94, 97, 121, 123, 201, 209, 213, 242, 251.

4. On October 14, 2025, the United States offered the defendant a plea

agreement, as the defendant recently expressed a desire to resolve the case

without proceeding to trial.

5. The trial is currently set to begin November 17, 2025. As set forth

below, the parties respectfully request that the trial in this case be moved to the

January 2026 trial term.

MEMORANDUM OF LAW

The parties agree that the ends of justice in continuing the trial to the

January 2026 trial term would outweigh the best interest of the public and the

defendant in a speedy trial. See 18 U.S.C. § 3161(h)(7)(A). Factors which the

court must consider include whether the failure to grant the continuance would be

likely to result in a miscarriage of justice, whether the case is so complex that it is

unreasonable to expect adequate preparation for trial within the time limits

established by the speedy trial statute, and whether failure to grant the

continuance would deny defense counsel the reasonable time necessary for

effective preparation, taking into account the exercise of due diligence. 18 U.S.C.

§ 3161(h)(B)(1), (ii), (iv).

Here, the defendant has recently expressed a desire to reach a resolution

2
Case 6:22-cr-00201-WWB-LHP Document 307 Filed 10/17/25 Page 3 of 5 PageID 1798

without a trial, and the United States extended a proposed plea agreement on

October 14, 2025. Given the complexity of the case and the needs of this

defendant, the parties anticipate that defense counsel will need a significant

amount of time to review the plea agreement with the defendant and to

potentially prepare him for a plea hearing. Alternatively, in the event that the

proposed plea agreement does not result in a resolution, defense counsel will

also need time to sufficiently prepare for a trial. Defense counsel, Andrew Searle,

has a complex federal fraud trial beginning the first week of November and will

largely be unavailable through mid-November because of that trial. Given that

Attorney Searle has the most established relationship with the defendant, he will

be needed to counsel the defendant on the plea offer. Thus, a continuance is

needed to provide sufficient time for the defendant to review the proposed plea

agreement with his counsel, to prepare for a plea hearing, and/or to proceed to

trial.

Additionally, the Government is still in the process of attempting to serve

trial subpoenas on witnesses it intends to call at trial. Given the length of time

that this case has been pending and the fact that multiple witnesses reside in

Canada, it has taken longer than anticipated to serve these witnesses. Moreover,

other government witnesses are federal employees of the United States Secret

Service, the Internal Revenue Service, and/or the Small Business Administration.

Given the current federal government shutdown, identifying and communicating

with these witnesses has also proven difficult. Thus, the Government also

3
Case 6:22-cr-00201-WWB-LHP Document 307 Filed 10/17/25 Page 4 of 5 PageID 1799

requests a continuance to allow sufficient time to prepare for trial, in the event

that the case is not resolved through a plea.

In view of the above circumstances, the parties respectfully request this

Court to continue the case for trial to the January 2026 trial term.

Respectfully submitted,

GREGORY W. KEHOE
United States Attorney

By: /s/ Kara M. Wick
KARA M. WICK
Assistant United States Attorney
Bar No. 0085578
400 W. Washington Street, Suite 3100
Orlando, Florida 32801
Telephone: (407) 648-7500
Facsimile: (407) 648-7643
E-mail: kara.wick@usdoj.gov

/s/Andrew C. Searle __________b
ANDREW C. SEARLE, ESQ.
Florida Bar No. 0116461
SEARLE LAW P.A.
200 East Robinson Street, Suite 1150
Orlando, Florida 32801
Telephone: 407-952-0642
Email: andrew@searle-law.com
Attorney for Defendant Joshua Edwards

4
Case 6:22-cr-00201-WWB-LHP Document 307 Filed 10/17/25 Page 5 of 5 PageID 1800

U.S. v. JOSHUA EDWARDS Case No. 6:22-cr-00201-WWB-LHP

CERTIFICATE OF SERVICE

I hereby certify that on October 17, 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:

Andrew Searle, Esq.
Corey Cohen, Esq.

/s/ Kara M. Wick
KARA M. WICK
Assistant United States Attorney
Bar No. 0085578
400 W. Washington Street, Suite 3100
Orlando, Florida 32801
Telephone: (407) 648-7500
Facsimile: (407) 648-7643
E-mail: kara.wick@usdoj.gov

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