Letter to Judge Berman, February 26, 2021, Re: United States v. Muge Ma, 20 CR 407 (RMB) (Dkt. 35, S.D.N.Y.)
Summary
In this February 26, 2021 letter to U.S. District Judge Richard M. Berman, Ma's defense counsel writes on behalf of the parties in United States v. Muge Ma, 20 CR 407 (RMB), to ask that the telephonic status conference set for March 3, 2021 be adjourned to the week of April 5, 2021 or later. The letter says that since the indictment was filed on August 17, 2020 the government has produced voluminous discovery and the parties have been in plea discussions, and that they are very close to a disposition and believe a trial is very unlikely. The parties ask that time be excluded under the Speedy Trial Act, and Assistant U.S. Attorney Sagar Ravi consents. The endorsement on the letter reads 'Application granted', adjourns the conference to April 5, 2021 at 12:00pm and excludes time, above a So Ordered line for Judge Berman.
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Case 1:20-cr-00407-RMB Document 38 Filed 02/26/21 Page,1 of 1 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 February 26, 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 the parties to request an adjournment of the telephonic status conference scheduled for March 3, 2021 until the week of April 5, 2021 or thereafter. As I have noted in a previous letter, since the indictment against Mr. Ma was filed on August 17, 2020, the government has produced voluminous discovery, and the parties have been engaged in on-going plea discussions that would obviate the need for a trial. We are very close to a disposition and firmly believe that a trial is very unlikely in this case. Accordingly, in order to allow time for the parties to complete our negotiations, the parties respectfully request that the March 3, 2021 conference be adjourned until April 5, 2021 or thereafter. The parties also respectfully request 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 parties submit that 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 April 5, 2021 at 12:00pm. a Time is excluded pursuant to the Petes Kae, Esq. Speedy Trial Act for the reasons set Counsel to Muge Ma forth in this letter. : SO ORDERED: Richard M. Berman, U.S.D.J.
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