Joint Motion to Continue Trial — United States v. Edwards (M.D. Fla., Document 319, December 17, 2025)

Summary

Joint motion filed December 17, 2025 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 in United States v. Joshua Edwards. The trial is set for the January 2026 trial term; the parties ask for the February 2026 trial term, unless the Court can set trial for the last week in January 2026. They state that the United States offered a plea agreement on October 14, 2025, that the defendant has not signed it, and that plea negotiations have recently ceased. The motion also cites the intervening holidays and witnesses, some of whom reside out of the country.

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“Joint Motion to Continue Trial — United States v. Edwards (M.D. Fla., Document 319, December 17, 2025).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-united-states-v-joshua-edwards-joint-dkt-319-m-d-fla-027d9d71f9/, SHA-256 4f191a25a3f0ffed1ef807b9479450196c68949b055014ef5dae4b162d3032c2.

Full text

Case 6:22-cr-00201-AGM-LHP Document 319 Filed 12/17/25 Page 1 of 5 PageID 1814

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 the January 2026 trial term, 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-AGM-LHP Document 319 Filed 12/17/25 Page 2 of 5 PageID 1815

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. The defendant has not signed the plea agreement and plea

negotiations have recently ceased.

5. The trial is currently set for the January 2026 trial term. As set forth

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

February 2026 trial term, unless the Court has availability to set the trial for the last

week in January 2026.

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
2
Case 6:22-cr-00201-AGM-LHP Document 319 Filed 12/17/25 Page 3 of 5 PageID 1816

the exercise of due diligence. 18 U.S.C. § 3161(h)(B)(1), (ii), (iv).

Here, recent efforts by both parties have been in attempting to reach a

resolution without the need for a trial. However, those efforts have not succeeded.

Given the complexity of the case and the needs of this defendant, both parties need

additional time to prepare for trial. Especially in light of the intervening holidays,

locating and preparing witnesses for trial, some of whom reside out of the country, is

a challenge. Additionally, defense counsel needs sufficient time to prepare the

defendant for a trial. Thus, unless the Court has availability to try the case during the

last week of January, the parties respectfully request that it be continued to the

February trial term.

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

continue the case for trial to the February 2026 trial term.

Respectfully submitted,

GREGORY W. KEHOE
United States Attorney

By: /s/Kara M. Wick______ /s/ Andrew C. Searle
Kara M. Wick ANDREW C. SEARLE, ESQ.
Assistant United States Attorney Florida Bar No. 0116461
Florida Bar No. 0085578 SEARLE LAW P.A.
400 W. Washington Street, Suite 3100 200 East Robinson Street, Suite 1150
Orlando, Florida 32801 Orlando, Florida 32801
Telephone: (407) 648-7500 Telephone: 407-952-0642
Facsimile: (407) 648-7643 Email: andrew@searle-law.com
E-mail: kara.wick@usdoj.gov Attorney for Joshua Edwards

/s/Corey Cohen
COREY COHEN, ESQ.

3
Case 6:22-cr-00201-AGM-LHP Document 319 Filed 12/17/25 Page 4 of 5 PageID 1817

Florida Bar No. 657840
21 Park Lake Street
Orlando, Florida 32803
Telephone: 407-246-0066
Email: corey@coreycohen.com
Attorney for Joshua Edwards

4
Case 6:22-cr-00201-AGM-LHP Document 319 Filed 12/17/25 Page 5 of 5 PageID 1818

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

CERTIFICATE OF SERVICE

I hereby certify that on December 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.

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

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