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Assented to Motion to Continue Trial — United States v. Reynolds (D. Mass., Document 59)

Summary

An Assented to Motion to Continue Trial filed November 3, 2025 as Document 59 by defendant Katherine Reynolds in United States v. Reynolds, Docket No. 24-cr-10233-MJJ, in the U.S. District Court for the District of Massachusetts. It asks to move the trial from December 1, 2025 to a later date after the resumption of the federal funding crisis, and to exclude the time under the Speedy Trial Act. The motion states that federal government funding expired at midnight on September 30, 2025 and that funding for the CJA panel ceased in mid-July. It cites the Criminal Justice Act, 18 U.S.C. § 3006A, and states that the AUSA assents. It is signed by counsel Joan M. Fund.

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“Assented to Motion to Continue Trial — United States v. Reynolds (D. Mass., Document 59).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-united-states-v-reynolds-dkt-59-d-mass-5428995eb6/, SHA-256 499763117a26d2400ff6bd684e9ce32c76bc59e9f156a282544c5d656a9d9c6e.

Full text

        Case 1:24-cr-10233-MJJ          Document 59        Filed 11/03/25       Page 1 of 3




                               UNITED STATES DISTRICT COURT
                                DISTRICT OF MASSACHUSETTS

UNITED STATES OF AMERICA

v.                                                            Docket No. 24-cr-10233-MJJ

KATHERINE REYNOLDS,
         Defendant


                        ASSENTED TO MOTION TO CONTINUE TRIAL

       The defendant respectfully moves this Honorable Court to continue the trial in this case

from December 1, 2025 to any date thereafter convenient with the Court and the parties that is

after the resumption of the federal funding crisis, and to exclude the time from to the date of the

hearing from the calculations of the Speedy Trial Act.

       As grounds for this motion, the defendant states:

       1. The Federal Government funding expired at midnight on September 30, 2025.

       2. Federal funding for CJA panel has ceased in mid-July.

       3. CJA counsel has not received payment for this or any federal case since prior to July.

       4. The defendant in the case at bar is not only indigent but is homeless and is currently

           residing in a homeless shelter.

       5. The defendant has no funds nor does the CJA appointed counsel have funds to provide

           transportation for meeting, court appearance or provide appropriate court clothing for the

           defendant.

       6. CJA is without funds to pay for use of an investigator, funds for printing, or other support

           needed for trial.

       7. The US Supreme Court on March 18, 1963 issued its decision in Gideon v. Wainwright,

           372 US 335 (1963) which guarantees the Sixth Amendment right to guarantee counsel.
Case 1:24-cr-10233-MJJ           Document 59        Filed 11/03/25     Page 2 of 3




8. In 1964 Congress enacted the Criminal Justice Act, 18 USC sec. 3006A (CJA) to

   “promote the cause of criminal justice by providing for the representation of defendants

   who are financially unable to obtain an adequate defense in criminal cases in the court

   of the United States.” Pub.L. 88-455, 78 Stat. 552.1

9. Beyond furnishing counsel, the CJA specifies that “[r]epresentation shall include

   counsel and investigative, expert, and other services necessary for adequate

   representation.” 18 U.S.C. § 3006A(a). See, United States v. Adams, 2025 U.S. Dist.

   LEXIS 187847, at *17 (D.D.C. Sep. 24, 2025).

10. The lack of funding for counsel and resources, the defendant submits, affects the

   defendant’s right to obtain an adequate defense as guaranteed by the Criminal Justice

   Act.

11. In the case at bar, the defendant is not in custody.

12. The AUSA assents to this continuance.

                                       Respectfully submitted,
                                       Katherine Reynolds
                                       By her attorney,

                                       /s/ Joan M. Fund
                                       Joan M. Fund, Esq.
                                       245 First Street
                                       Suite 1800
                                       Cambridge, MA 02142
                                       617 444 8762
                                       508 878 6830
                                       BBO#181430
        Case 1:24-cr-10233-MJJ          Document 59        Filed 11/03/25      Page 3 of 3




                                 CERTIFICATE OF SERVICE

        I hereby certify that this document filed through the ECF system will be sent
electronically to the registered participants as identified on the Notice of Electronic Filing (NEF).

                                              /s/ Joan M. Fund
                                              Joan M. Fund, Esquire
Date: November 3, 2025

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