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