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Defendant’s Motion for Remand to State Custody — No. 4:21-cr-00640 (Dkt. 18, E.D. Mo.)

Summary

A defendant's motion for remand to state custody filed in the U.S. District Court for the Eastern District of Missouri, Eastern Division, in United States v. Eugene Times, Case No. 4:21-CR-00640-AGF-SRW, as filing 18 of 2 pages, dated June 6, 2023. Through Assistant Federal Public Defender Tyler K. Morgan, Times asks the Court to direct the United States Marshals Service to return him to the custody of the State of Missouri. He states that the Government does not oppose, that he is in federal custody on a writ of habeas corpus ad prosequendum and so in primary state custody, that at his May 23, 2023 initial appearance he waived a detention hearing and was ordered detained, and that his state jury trial in the City of St. Louis is set for July 31, 2023 with a pretrial conference on July 13, 2023.

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“Defendant’s Motion for Remand to State Custody — No. 4:21-cr-00640 (Dkt. 18, E.D. Mo.).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/defendant-s-motion-for-remand-to-state-custody-no-4-21-cr-00640-dkt-18-5a9a43b673/, SHA-256 81ff97711e768cfed09c7967b346500d7f112ef462c3a2648809767ffd491371.

Full text

     Case: 4:21-cr-00640-AGF-SRW Doc. #: 18 Filed: 06/06/23 Page: 1 of 2 PageID #: 36




                           UNITED STATES DISTRICT COURT
                       FOR THE EASTERN DISTRICT OF MISSOURI
                                 EASTERN DIVISION


UNITED STATES OF AMERICA                      )
                                              )
                          Plaintiff,          )
                                              )
v.                                            ) Case No. 4:21-CR-00640-AGF-SRW
                                              ) Case No. 4:22-CR-00371-AGF-SRW
EUGENE TIMES,                                 )
                                              )
                          Defendant.          )


              DEFENDANT’S MOTION FOR REMAND TO STATE CUSTODY

        Defendant Eugene Times, through Assistant Federal Public Defender Tyler K.

Morgan, respectfully requests that this Honorable Court enter an order directing the United

States Marshals Service (USMS) to transfer him back to the custody of the State of Missouri.

In support, he states:

        1. The Government does not oppose this request.

        2. Mr. Times is in federal custody on a writ of habeas corpus ad prosequendum from

the State of Missouri. Accordingly, he is in primary state custody. He appeared before the

Court on May 23, 2023, for an initial appearance, arraignment, and detention hearing. At

that time, he waived his right to a detention hearing and was ordered detained. (Docs. 11

& 14, respectively).

        3. Mr. Times is scheduled to appear for a jury trial in Case Nos. 2122-CR01536-01

and 2222-CR01688-01 in the City of St. Louis on July 31, 2023, with a pretrial conference

scheduled for July 13, 2023. Counsel has spoken with Mr. Times’s state attorney, and he is
  Case: 4:21-cr-00640-AGF-SRW Doc. #: 18 Filed: 06/06/23 Page: 2 of 2 PageID #: 37




prepared to announce ready for trial on the current date. If the Court authorizes his return

to state custody, Mr. Times will have the opportunity to appear for trial to avoid any further

continuances in that matter.

      4. If remanded back to state custody, this Court can be assured that Mr. Times will

not be released before the resolution of his state charges because he is currently being

detained without bond in those matters.

      WHEREFORE, Mr. Times requests that this Honorable Court grant his request for

temporary transfer to state custody.

                                              Respectfully submitted,


                                               /s/ Tyler K. Morgan
                                               TYLER K. MORGAN
                                               Assistant Federal Public Defender
                                               1010 Market Street, Suite 200
                                               St. Louis, Missouri 63101
                                               Telephone: 314-241-1255
                                               Fax: 314-241-3177
                                               E-Mail: tyler_morgan@fd.org
                                               Attorney for Mr. Times


                               CERTIFICATE OF SERVICE

       Assistant Federal Public Defender Tyler K. Morgan certifies that he filed the
foregoing via the Court’s electronic filing system, leading to service upon Assistant United
States Attorney Nauman Wadalawala via email.

      Dated June 6, 2023.
                                               /s/ Tyler K. Morgan
                                               TYLER K. MORGAN
                                               Attorney for Mr. Times

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