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Home Source documents Letter to Judge Berman, May 17, 2021, Re: United States v. Muge Ma, 20 CR 407 (RMB) (Dkt. 43, S.D.N.Y.)

Letter to Judge Berman, May 17, 2021, Re: United States v. Muge Ma, 20 CR 407 (RMB) (Dkt. 43, S.D.N.Y.)

Summary

In a May 17, 2021 letter to U.S. District Judge Richard M. Berman in United States v. Muge Ma, 20 CR 407 (RMB) (S.D.N.Y.), defense counsel Peter Katz writes that the parties have come to terms on a plea agreement, but Mr. Ma's signature is not yet in hand because of difficulty sending and receiving mail at the MCC, where Mr. Ma is housed. The letter says Mr. Ma wants to plead in open court in person and, if that cannot happen at the status conference set for May 19, 2021, asks for a brief adjournment and the exclusion of time under the Speedy Trial Act, with the consent of Assistant U.S. Attorney Sagar Ravi. Judge Berman's endorsement reads 'Application granted', schedules an in-person plea proceeding for Thursday, June 3, 2021 at 11:30 AM and excludes time under the Speedy Trial Act.

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Case 1:20-cr-00407-RMB Document 42 Filed OS/17/At Page,1 of 1
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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

May 17, 2021
BY ECF
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 regarding the current telephonic status conference scheduled for Wednesday, May 19, 2021.
As Your Honor is aware, we have been working with the government on a plea agreement. We
have come to terms. However, because of the difficulty in sending and receiving mail from the
MCC, where Mr. Ma is housed, I do not yet have his signature on the plea agreement.

In addition, in preparing Mr. Ma for the plea colloquy, Mr. Ma has determined, for a variety
of reasons, that he would like to plead in open court in person. If this is possible on this
Wednesday, we would be able to appear in person. If it is not, we respectfully request a brief
adjournment so that Your Honor can set an in person plea proceeding.

In the event that there is an adjournment, 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 potential adjournment request and to the exclusion of time on behalf of the government.

Thank you for your attention to this matter.

OULEVARD, SUITE 200

Application granted. In-person pléa
proceeding is scheduled for Thursday,
June 3, 2021 at 11:30 AM. Time is
excluded pursuant to the Speedy Trial
Act for the reasons set forth in this
letter.

SO ORDERED:

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

Sincerely,

Peter Katz, Esq.
Counsel to Muge Ma


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