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Defense Counsel Letter to Judge Russell — United States v. Ryan Dales (Dkt. 54)

Summary

A letter dated 20 December 2023 from Richard Bardos, Of Counsel, at Schulman, Hershfield & Gilden, P.A., to Judge George L. Russell in United States v. Ryan Dales, Document 54 in Case 1:23-cr-00026-GLR. The letter says it is written to represent Mr. Dales in the indictment and states that on October 10, 2023, a motion to sever and a motion to suppress the search on January 20, 2023 were filed. It states that the Government has not yet responded to either motion and that no trial date is set. The letter requests that the Court set a briefing schedule and hearing date for the defendant's pending motions.

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Cite this document

“Defense Counsel Letter to Judge Russell — United States v. Ryan Dales (Dkt. 54).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-mdd-529188-54-0-64489d48c7/, SHA-256 b69f0dbec771e43db92a5cdd823817104c5489b913197262715a15cfd8d313f1.

Full text

         Case 1:23-cr-00026-GLR         Document 54        Filed 12/20/23      Page 1 of 1



                SCHULMAN, HERSHFIELD & GILDEN, P.A.
                                    ATTORNEYS AT LAW
                                  ONE EAST PRATT STREET
                                         SUITE 904
                                BALTIMORE, MARYLAND 21202
                                       (410) 332 0850
                                     FAX (410) 332 0866

rbardos@shg-legal.com
                                                      20 December 2023
VIA ECF
George L. Russell, Judge
United States District Court
For the District of Maryland
101 W. Lombard Street
Baltimore, Maryland 21202

                               RE: United States v. Ryan Dales
                               Case No. GLR-23-206

Dear Judge Russell:

        I represent Mr. Dales in the above-captioned indictment. Mr. Dales is charged in a seven
count superseding indictment with three entirely separate offenses - different in kind, distant in
time and unrelated to each other, but for Dales being the defendant in each. On October 10,
2023, I filed a motion to sever each of these crimes and for separate trials on each. ECF 50. On
the same date, I filed a motion to suppress the search on January 20, 2023, on timeliness grounds.
The Government has not yet responded to either motion. In addition, to date, no trial date is set
in this matter.

        I am writing to request that the Court set in a briefing schedule and hearing date for the
defendant’s pending motions. I believe the Court’s decisions on these motions will assist the
parties in determining whether a resolution short of trial is possible.

       Thank you for your consideration of this request.

                                              Very truly yours,

                                              Richard Bardos, Of Counsel
RBB:rb

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