Letter to Judge Russell — United States v. Ryan Dales (District of Maryland, Document 87, 5 November 2024)

Summary

A letter dated 5 November 2024 from Richard Bardos, Of Counsel at Schulman, Hershfield & Gilden, P.A., to Chief Judge George L. Russell in United States v. Ryan Dales, Case No. GLR-23-026, filed 11/05/24 as Document 87 in Case 1:23-cr-00026-GLR, U.S. District Court for the District of Maryland. It seeks clarity on the Court's October 30, 2024 scheduling Order, which set a trial date for the fraud related charges and a "Pretrial Conference/Motions Hearing". The letter asks whether the Order refers to the defendant's motion for reconsideration, ECF 76, and if so asks for a hearing on that motion before the drug/guns trial set for December 2, 2024. It states that all of the evidence for that trial was seized in the search at issue and disagrees with the Government's suggestion that the motion be denied without a hearing.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Full text

       Case 1:23-cr-00026-GLR          Document 87         Filed 11/05/24    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                                               5 November 2024

VIA ECF
George L. Russell, Chief Judge
United States District Court for
the District of Maryland
01 W. Lombard Street
Baltimore, Maryland 21201

                              RE: United States v. Ryan Dales
                              Case No. GLR-23-026

Dear Judge Russell:

        On October 30, 2024, Your Honor issued a scheduling Order setting the trial date for the
fraud related charges, to be held in January, 2025. In the order, the Court also stated that a
“Pretrial Conference/Motions Hearing” would be held on Januayr 9, 2025. I am writing to seek
some clarity on this latter part of the Order.

        The only pending motion is the defendant’s motion for reconsideration of the Court’s
denial of his motion to suppress. I’m wondering whether it is this motion, ECF 76, to which the
Court is referring in the October 30, 2024, Order. If so, I would aks the Court to consider
holding a hearing on that motion prior to the drug/guns trial set for December 2, 2024. All of the
evidence to be introduced at the drug/guns trial was seized in the search at issue in the current
motion. Waiting until the drug/gun trial is over to decide the motion effectively moots the
motion with regard to that evidence.

       In its opposition to the motion, the Government suggests that the motion be denied
without a hearing. The defense would respectfully disagree with that request and ask that the
Court hold a hearing on the motion before December 2, 2024, if at all possible.

       Thank you for your consideration of this request.

                                             Very truly yours,

                                             Richard Bardos, Of Counsel
RBB:rb
Cc: All Counsel via ECF


File and source

File

gov.uscourts.mdd.529188.87.0.pdf

Size

130,251 bytes

SHA-256

603dc02d0b6d88cae7b15a2dc06708dae91f96dbc1797a4357ca958aabc4be0a

Our copy

gov.uscourts.mdd.529188.87.0.pdf

Original

No public link identified.