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Unopposed Motion for Extension of Time to Indict — United States v. Gregory Scott Keough (Dkt. 15)

Summary

An Unopposed Motion for Extension of Time to Indict entered on the docket August 21, 2023 as Document 15 in United States v. Gregory Scott Keough, Case No. 23-MJ-8393-WM, in the U.S. District Court for the Southern District of Florida. The United States and Gregory Scott Keough, through their respective undersigned counsel, move for an order under the Speedy Trial Act excluding the time from August 23, 2023 to August 25, 2023. The motion states that the parties wish to have additional time for pre-trial discussion relating to pre-trial detention and/or bond or an alternate resolution. It states that the defendant, through counsel, waives the right to a speedy indictment for that period. The signature block names Assistant United States Attorney Robin W. Waugh.

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Cite this document

“Unopposed Motion for Extension of Time to Indict — United States v. Gregory Scott Keough (Dkt. 15).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-flsd-651999-15-0-69859e85fb/, SHA-256 fc747961daff7517ddde1093ba8997ccbb0a4c6dffa48954522f3bdc3313209e.

Full text

Case 9:23-mj-08393-WM Document 15 Entered on FLSD Docket 08/21/2023 Page 1 of 3




                              UNITED STATES DISTRICT COURT
                              SOUTHERN DISTRICT OF FLORIDA

                                     CASE NO. 23-MJ-8393-WM

  UNITED STATES OF AMERICA

  vs.

  GREGORY SCOTT KEOUGH,

                    Defendant.
  __________________________________________/

              UNOPPOSED MOTION FOR EXTENSION OF TIME TO INDICT

         The United States of America and Gregory Scott Keough, through their respective

  undersigned counsel, hereby move the Court to enter an order under the Speedy Trial Act, 18

  U.S.C. § 3161(h)(7), excluding the time that elapses from August 23, 2023 to August 25, 2023,

  from calculation of the deadlines set forth in the Act and extending the date by which this matter

  must be indicted. In support of this motion, the parties state the following:

         The extension of time to indictment from August 23, 2023 to August 25, 2023, is filed on

  the grounds that the parties wish to have an additional period of time in which to engage in pre-

  trial discussion relating to pre-trial detention and/or bond or an alternate resolution to this case.

         The defendant, through counsel, waives his right to a speedy indictment and agrees that the

  time from August 23, 2023 to August 25, 2023, should be excluded under the Speedy Trial Act,

  18 U.S.C. § 3161(h)(7), from calculation of the deadlines set forth in the Act, and waives his rights

  under the Act for that requested period of exclusion. The interest of justice to be served by the

  requested exclusion of time outweigh the interest of the defendant and the public in a speedy trial

  because the charges herein are very serious and the potential to resolve the case by agreement

  would promote a speedy and certain outcome of the case.
Case 9:23-mj-08393-WM Document 15 Entered on FLSD Docket 08/21/2023 Page 2 of 3




         The undersigned Assistant United States Attorney has conferred with David Joffe, counsel

  to Defendant Gregory Scott Keough, who does not object to this filing.

         WHEREFORE, the parties respectfully request that the Court enter an Order excluding the

  period of time from August 23, 2023 to August 25, 2023, should be excluded from calculation

  under the provisions of the Speedy Trial Act.

                                                     Respectfully submitted,

                                                     MARKENZY LAPOINTE
                                                     UNITED STATES ATTORNEY

                                                     /s/ Robin W. Waugh
                                                     ROBIN W. WAUGH
                                                     Assistant United States Attorney
                                                     Florida Bar #: 537837
                                                     500 South Australian Avenue, 4th Flr.
                                                     West Palm Beach, Florida 33401
                                                     Tel: (561) 820-8711
                                                     Fax: (561) 659-4526
                                                     Robin.waugh@usdoj.gov
Case 9:23-mj-08393-WM Document 15 Entered on FLSD Docket 08/21/2023 Page 3 of 3




                                 CERTIFICATE OF SERVICE

        I hereby certify that on August 21, 2023, the undersigned electronically filed the foregoing

  document with the Clerk of the Court using CM/ECF.

                                            /s/ Robin W. Waugh
                                            ROBIN W. WAUGH
                                            Assistant United States Attorney

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