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Defendant’s Unopposed Motion for Continuance to the Honorable Judge of Said Court — No. 4:20-cr-00583 (Dkt. 97, S.D. Tex.)

Summary

A defendant's unopposed motion for continuance filed in the U.S. District Court for the Southern District of Texas, Houston Division, in United States v. Amir Aqeel, Case No. 4:20-cr-583, docketed as 4:20-cr-00583, as Document 97 of 4 pages. Aqeel states that a telephone hearing on his motion concerning detention and bail is scheduled for Wednesday, April 21, 2021 at 2:00 P.M., that defense counsel needs to review the government's supplemental response materials, including references to recordings in Urdu that have not been officially translated or turned over, and that counsel for the United States agreed by email not to oppose a continuance. Citing the Speedy Trial Act, 18 U.S.C. 3161(h)(7)(A) and (B)(iv), he asks for an order finding that the ends of justice are served by the delay. A proposed order for the Honorable Andrew S. Hanen follows.

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Cite this document

“Defendant’s Unopposed Motion for Continuance to the Honorable Judge of Said Court — No. 4:20-cr-00583 (Dkt. 97, S.D. Tex.).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/defendant-s-unopposed-motion-for-continuance-to-the-honorable-judge-of-dd0c224a4b/, SHA-256 f45047d51baf4db8cf2171a149b6a756de5241fa42f90657b0df7a349a57905d.

Full text

      Case 4:20-cr-00583 Document 97 Filed on 04/20/21 in TXSD Page 1 of 4



                          UNITED STATES DISTRICT COURT
                           SOUTHERN DISTRICT OF TEXAS
                               HOUSTON DIVISION

UNITED STATES OF AMERICA                        §
                                                §
v.                                              §
                                                §
AMIR AQEEL,                                     §         CASE NO.: 4:20-cr-583
     Defendant



             DEFENDANT’S UNOPPOSED MOTION FOR CONTINUANCE

       TO THE HONORABLE JUDGE OF SAID COURT:

       NOW COMES AMIR AQEEL, by and through his respective undersigned counsel, and

bring this Unopposed Motion for Continuance, and in support hereof, Defendant would show the

court the following:

       1.      A telephone hearing has been set on Defendant’s Motion to Amend or Reconsider

Order of Detention Pending Trial and Request to set Bail.           The hearing is scheduled for

Wednesday, April 21, 2021 at 2:00 P.M.

       2.      The government’s supplemental response materials that Defense Counsel needs to

review in order to provide effective assistance. This includes references to recordings in Urdu,

that have not been officially translated, nor turned over to Defense Counsel.

       3.      Counsel for Defendant has conferred with Counsel for the United States in an

email thread and have agreed not to oppose a continuance if this Court would so allow.

       4.      Pursuant to the Speedy Trial Act, §§ 18 U.S.C. 3161(h)(7)(A) and (B)(iv),

defense counsel requests the court to enter an order granting a continuance on the basis that the

ends of justice will be served by allowing defense counsel the reasonable time necessary to

review discovery and investigate possible defenses to the allegations.



                                            Page 1 of 5
      Case 4:20-cr-00583 Document 97 Filed on 04/20/21 in TXSD Page 2 of 4




       5.      This Motion is not made for purposes of delay, but so that justice might be served.

       6.      WHEREFORE, PREMISES CONSIDERED, Defendant respectfully pray that

this Honorable Court will grant this Motion for Continuance thereby continuing the telephonic

hearing scheduled for Wednesday, April 21, 2021 at 2:00 p.m.

       Respectfully submitted,

                                             MINGLEDORFF LAW FIRM
                                             /s/Kenneth P. Mingledorff
                                             KENNETH P. MINGLEDORFF, ATTORNEY
                                             TBA 14176800
                                             SDTX Bar ID: 1735
                                             ken@mingledorfflaw.com
                                             TOMMY T. MINGLEDORFF, ATTORNEY
                                             TBA 24104542
                                             SDTX Bar ID: 3435336
                                             tommy@mingledorfflaw.com
                                             JUDY P. MINGLEDORFF, ATTORNEY
                                             TBA 16088675
                                             SDTX Bar ID: 1672
                                             judy@mingledorfflaw.com
                                             430 Highway 6 S., Suite 215
                                             Houston, Texas 77079
                                             281-497-7180 telephone
                                             281-497-4150 fax
                                             ATTORNEYS FOR AMIR AQEEL



                               CERTIFICATE OF CONFERENCE

       I hereby certify that Defense Counsel and all Counsel for the United States have

conferred in an email thread regarding the matters described above and received confirmation

that the government does not oppose a continuance of the Wednesday April 21, 2021 hearing

setting, as described above.

                                 CERTIFICATE OF SERVICE




                                            Page 2 of 5
      Case 4:20-cr-00583 Document 97 Filed on 04/20/21 in TXSD Page 3 of 4




          IT IS HEREBY CERTIFIED that service of a true and correct copy of the foregoing has

been made by electronic means or U.S. mail, on Tuesday, April 20, 2021 to all attorneys of

record.

          Financial Litigation
          U S Attorney's Office
          Southern District of Texas
          1000 Louisiana St
          Ste 2300
          Houston, TX 77002
          713-567-9000
          713-718-3391 fax (fax)
          flu.usatxs-@usdoj.gov

          Louis Manzo
          Department of Justice
          1400 New York Ave NW
          Washington, DC 20005
          202-262-6570
          louis.manzo@usdoj.gov

          Rodolfo Ramirez
          United States Attorney's Office
          1000 Louisiana St
          Ste 2300
          Houston, TX 77002
          713-567-9000
          rodolfo.ramirez@usdoj.gov

          Della Grace Sentilles
          United States Department of Justice
          1400 New York Avenue NW
          Third Floor
          Washington, DC 20005
          202-445-8793
          della.sentilles@usdoj.gov


                                                 /s/Kenneth P. Mingledorff
                                                 KENNETH P. MINGLEDORFF, ATTORNEY
                                                 ATTORNEY FOR AMIR AQEEL




                                                Page 3 of 5
        Case 4:20-cr-00583 Document 97 Filed on 04/20/21 in TXSD Page 4 of 4



                           UNITED STATES DISTRICT COURT
                            SOUTHERN DISTRICT OF TEXAS
                                HOUSTON DIVISION

UNITED STATES OF AMERICA                        §
                                                §
v.                                              §
                                                §
AMIR AQEEL,                                     §     CASE NO.: 4:20-cr-583
     Defendant



                                            ORDER

         Pursuant to the Speedy Trial Act, 18 U.S.C. Section 3161(h)(7)(A), the Court finds that

the ends of justice will be served by allowing the defendants additional time in which to prepare

this case and these findings outweigh the best interest of the public and the defendants in a

speedy trial. The Court’s basis for said finding is that the failure to grant a continuance in this

case would deny counsel for the defendants the reasonable time necessary for effective

preparation, taking into account the exercise of due diligence. See 18 U.S.C. §3161(h)(B)(iv).



         IT IS HEREBY ORDERED that Defendants’ Unopposed Motion for Continuance is

hereby GRANTED. Defendant’s Hearing will now be held on _________________________,

2021.

         SIGNED AND ENTERED, on this the _____ day of ______________, 20__.

                                                     ____________________________________
                                                     THE HONORABLE ANDREW S. HANEN
                                                     UNITED STATES DISTRICT COURT


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