Government Letter to Chief Judge Russell — United States v. Ryan Dales (Dkt. 67)

Summary

A letter dated September 6, 2024, to The Honorable George L. Russell III, Chief United States District Judge, in United States v. Ryan Dales, Crim. No. GLR-23-026, Document 67 in Case 1:23-cr-00026-GLR. Written on behalf of the Government, it requests that the Court order a Lafler/Frye hearing to establish the terms of the plea offer made to the Defendant, that the offer was communicated, and that the Defendant rejected it. It says the purpose is a clear record if the Defendant later brings a claim under 28 U.S.C. § 2255. The letter states that counsel for the Defendant does not object and asks for an Order of Reference to a Magistrate Judge to conduct the hearing, if possible in the next few weeks.

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Full text

           Case 1:23-cr-00026-GLR       Document 67         Filed 09/06/24      Page 1 of 1
                                                     U.S. Department of Justice
                                                     United States Attorney
                                                     District of Maryland

Paul Riley                                           Suite 400                      DIRECT: 410-209-4959
Assistant United States Attorney                     36 S. Charles Street             MAIN: 410-209-4800
Paul.Riley@usdoj.gov                                 Baltimore, MD 21201-3119          FAX: 410-962-3091



                                                                       September 6, 2024
BY ECF
The Honorable George L. Russell III
Chief United States District Judge
United States District Court for the District of Maryland
United States Courthouse
101 West Lombard Street
Baltimore, MD 21201

Re:        United States v. Ryan Dales, Crim. No. GLR-23-026
Dear Chief Judge Russell:
        I write on behalf of the Government in the above-referenced matter to request respectfully
that the Court order a Lafler/Frye hearing in this matter to establish the terms of the plea offer
made to the Defendant, the fact that the plea offer was communicated to the Defendant, and the
fact that the Defendant rejected the plea offer.
        The purpose of such a hearing is plain: To ensure there is a clear record in the event the
Defendant subsequently brings a claim under 28 U.S.C. § 2255 alleging that his attorney failed to
effectively convey any plea offer. Further, such a hearing is warranted in light of the significant
sentencing exposure the Defendant will face if he is convicted after his trials before Your
Honor, which are currently set to begin on December 2, 2024.
        Undersigned counsel has conferred with counsel for the Defendant concerning this
request for a Lafler/Frye hearing; he does not object to it. Accordingly, the Government
respectfully requests that the Court issue an Order of Reference to a Magistrate Judge for the
purpose of conducting a Lafler/Frye hearing. Further, if the Court is amenable to it, the
Government respectfully requests that the hearing be held promptly—if possible, in the next few
weeks.
                                                     Respectfully submitted,

                                                     Erek L. Barron
                                                     United States Attorney

                                                       /s/
                                             By:     Paul A. Riley
                                                     Assistant United States Attorney


CC: All counsel (by ECF)


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