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Home Source documents Letter to Judge Berman, April 28, 2021, Re: United States v. Muge Ma, 20 CR 407 (RMB) (Dkt. 40, S.D.N.Y.)

Letter to Judge Berman, April 28, 2021, Re: United States v. Muge Ma, 20 CR 407 (RMB) (Dkt. 40, S.D.N.Y.)

Summary

In this April 28, 2021 letter to U.S. District Judge Richard M. Berman, defense counsel Peter Katz asks to adjourn the telephonic status conference set for May 3, 2021 in United States v. Muge Ma, 20 CR 407 (RMB), and to convert it into a guilty plea colloquy. Katz writes that the government has provided a finalized plea agreement and that the parties agree on its material terms, but that difficulty communicating with Ma during the COVID pandemic, and Ma's difficulty using the law library, leave the defense unready to plead on May 3. The letter asks for the week of May 17 or May 24 and for time to be excluded under the Speedy Trial Act, and says Assistant U.S. Attorney Sagar Ravi consents. The endorsement printed on the letter reads 'Application granted', adjourns the conference to May 19, 2021 at 10:30 AM and excludes time, above a So Ordered line for Judge Berman.

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Case 1:20-cr-00407-RMB Document 39 Filed 04/28/21 Page,1 of 1
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16 VILLAGE BOULEVARD, SUITE 200
AW O FFICES OF PRINCETON, NEw JERSEY 08540

609.734-4380

P E; T EB R KAT 7, 52 Duane Srreer, 7TH FLoor

New York, New YorK 10007
212.933-9323
EXPERIENCE DEDICATION RESULTS PKATZLEGAL.COM

April 28, 2021
BY EMAIL
Hon. Richard M. Berman
United State District Judge
Southern District of New York
500 Pearl Street
New York, New York 10007

Re: United States v. Muge Ma, 20 CR 407 (RMB)

Dear Judge Berman:

I am counsel to Mr. Ma in the above referenced case. I submit this letter on behalf of
Mr.Ma to request an adjournment of the telephonic status conference scheduled for May 3, 2021
until later in May 2021 and to convert that conference into a guilty plea colloquy.

The government has provided me with a finalized version of the plea agreement, which I
have mailed to Mr. Ma. We are in agreement on the material terms, however, because of the
difficulty communicating with Mr. Ma due to the COVID pandemic as well as his difficulty using
the law library, we will not be prepared to plead on May 3". Accordingly, in order to allow time
for us to adequately prepare for the plea, we respectfully request that the May 3, 2021 conference
be adjourned until the week of May 17" or May 24".

We respectfully request and consent that time be excluded under the Speedy Trial Act until
the next conference date set by the Court pursuant to Title 18, United States Code, Section
3161(h)(7)(A). The exclusion of time best serves the ends of justice and outweighs the best
interests of the public and the defendant in a speedy trial as it will allow time for the parties to
continue our on-going discussions regarding a potential disposition of this matter. I have consulted
with Assistant U.S. Attorney Sagar Ravi who consents to this adjournment request and to the
exclusion of time on behalf of the government.

Thank you for your attention to this matter.

Application granted. Conference “ Sincerely,
adjourned to May 19, 2021 at 10:30 AM. iS)

Time is excluded pursuant to the Speedy cS

Trial Act for the reasons set forth in this Peter Katz, Esq.
letter. Counsel to Muge Ma

SO ORDERED:

Richard M. Berman, U.S.D.J.


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