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Defendant’s Unopposed Motion to Continue Trial — No. 1:22-cr-00032 (Dkt. 19, N.D. Fla.)

Summary

A defendant's unopposed motion to continue trial filed in the U.S. District Court for the Northern District of Florida, Gainesville Division, in United States v. Joseph Harding, Case No. 1:22-cr-32-AW-MAL, docketed as 1:22-cr-00032, as Document 19 of 3 pages. Harding asks that the trial, scheduled for January 11, 2023, be continued to the May 2023 docket. The motion states that Assistant United States Attorney Justin M. Keen does not oppose, that Keen has a scheduling conflict in another trial from mid-February to mid-March with annual leave in April, that the Government is preparing discovery materials for the defense, and that the request is made in good faith and will prejudice neither party. It is signed by Peggy-Anne O'Connor as counsel for the defendant.

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Cite this document

“Defendant’s Unopposed Motion to Continue Trial — No. 1:22-cr-00032 (Dkt. 19, N.D. Fla.).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/defendant-s-unopposed-motion-to-continue-trial-no-1-22-cr-00032-dkt-19-13fcbf8c6d/, SHA-256 710bbe36509939166938c10b2990aefb2d2387d78115400a4cc9f7a2cf993bf2.

Full text

         Case 1:22-cr-00032-AW-MAL Document 19 Filed 12/19/22 Page 1 of 3




                      IN THE UNITED STATES DISTRICT COURT
                         NORTHERN DISTRICT OF FLORIDA
                              GAINESVILLE DIVISION



UNITED STATES OF AMERICA,

         Plaintiff,                                  CASE NO: 1:22-cr-32-AW-MAL

vs.

JOSEPH HARDING,

     Defendant.
___________________________/


        DEFENDANT’S UNOPPOSED MOTION TO CONTINUE TRIAL

         Defendant JOSHEPH HARDING, through undersigned counsel, files this

unopposed motion to continue the trial to the May 2023 docket. In support thereof,

Defendant states as follows:

      1. Assistant United States Attorney Justin M. Keen has authorized undersigned

counsel to represent to this Court that he does not oppose the relief requested.

      2. Trial is currently scheduled for January 11, 2023.

      3. Assistant United States Attorney Keen has also authorized undersigned

counsel to represent that he has a scheduling conflict in another trial from mid-

February to mid-March with annual leave time scheduled in April.

      4. The Government is preparing discovery materials to provide to the defense.
      Case 1:22-cr-00032-AW-MAL Document 19 Filed 12/19/22 Page 2 of 3




   5. This motion is made in good faith and not for the purpose of unnecessary

delay. Additionally, neither party will be prejudiced by granting this requested

action.

      THEREFORE, Defendant respectfully requests that this Court enter an

   Order continuing the trial to the May 2023 docket.

                      CERTIFICATE OF COMPLIANCE
                      STATEMENT OF CONSULTATION

      Pursuant to Local Rule 7.1(B) of the United States District Court for the

Northern District of Florida, I hereby certify that I have consulted on this matter

with United States Attorney Justin M. Keen, who has authorized me to represent to

the Court that he has no objection to the relief requested.

                      CERTIFICATE OF COMPLIANCE
                         MEMORANDUM OF LAW

      Pursuant to Local Rule 7.1(G)(1) of the United States District Court for the

Northern District of Florida, no Memorandum of Law is required as the motion is

unopposed and all parties stipulate to the relief sought.

                          CERTIFICATE OF SERVICE

      I HEREBY CERTIFY that a true and correct copy of the foregoing

document has been electronically delivered via CM/ECF to the following:

                          Justin M. Keen, Esq.
                          U.S. Attorney’s Office
                          111 North Adams Street, 4th Floor
                          Tallahassee, FL 32301
      Case 1:22-cr-00032-AW-MAL Document 19 Filed 12/19/22 Page 3 of 3




                         Justin.keen@usdoj.gov


Respectfully submitted this 19th day of December, 2022.

                               TURNER O’CONNOR KOZLOWSKI, P.L.


                               /s/   Peg O’Connor
                               PEGGY-ANNE O’CONNOR
                               Florida Bar No. 170471
                               peg@toklegal.com
                               102 N.W. Second Avenue
                               Gainesville, FL 32601
                               (352) 372-4263
                               Secondary E-mail: eservice@toklegal.com

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