Letter to Judge Berman Re: United States v. Muge Ma, 20 Cr. 407 (RMB) (Dkt. 28, S.D.N.Y.)
Summary
In a December 3, 2020 letter to U.S. District Judge Richard M. Berman in United States v. Muge Ma, 20 Cr. 407 (RMB), the Government, for both parties, asks to adjourn the December 7, 2020 telephonic status conference until the week of January 18, 2021 or later. The letter recounts that Muge Ma was indicted on August 17, 2020 on counts including major fraud against the United States, bank fraud, wire fraud, false statements and aggravated identity theft, over an alleged effort to obtain over $20 million in Government-guaranteed loans meant for small businesses. It says voluminous discovery has been produced and the parties are in plea discussions, and asks to exclude time under the Speedy Trial Act, with the consent of defense counsel Peter Katz. The endorsement on the letter reads 'Application granted' and adjourns the conference to Wednesday, January 27, 2021 at 9:00 am.
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Case 1:20-cr-00407-RMB Document 27
28 Filed 12/03/20 Page 1 of 2
U.S. Department of Justice
[Type text]
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew’s Plaza
New York, New York 10007
December 3, 2020
BY ECF
The Honorable Richard M. Berman
United States 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:
The Government respectfully submits this letter on behalf of the parties in the above-
referenced case to request an adjournment of the telephonic status conference scheduled for
December 7, 2020 until the week of January 18, 2021 or thereafter.
As the Court is aware, on August 17, 2020, the defendant Muge Ma was indicted on
multiple counts involving major fraud against the United States, bank fraud, wire fraud, false
statements, and aggravated identity theft, in connection with a fraudulent scheme to obtain over
$20 million in Government-guaranteed loans designed to provide relief to small businesses during
the novel coronavirus/COVID-19 pandemic. Since that time, the Government has produced a
voluminous amount of discovery to the defendant, and the parties have been engaged in ongoing
discussions regarding a potential pretrial disposition of this case. Accordingly, in order to allow
time for the parties to complete our plea discussions, the parties respectfully request that the
December 7, 2020 conference be adjourned for approximately six weeks until the week of January
18, 2021 or thereafter.
Finally, the Government respectfully requests 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 Government submits 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 ongoing discussions regarding a potential disposition of this
Case 1:20-cr-00407-RMB Document 27
28 Filed 12/03/20 Page 2 of 2
December 3, 2020
Page 2
matter. The Government has consulted with defense counsel Peter Katz, Esq., who consents to
the exclusion of time on behalf of the defendant.
Respectfully submitted,
AUDREY STRAUSS
Acting United States Attorney
By: _____________________________
Sagar K. Ravi
Assistant United States Attorneys
(212) 637-2195
Application granted. Conference is
adjourned to Wednesday, January 27,
2021 at 9:00 am. Time is excluded
pursuant to the Speedy Trial Act for the
reasons set forth in this letter.
11/3/2020
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