Letter to Judge Berman Re: United States v. Muge Ma, 20 CR 407 (RMB) (Dkt. 32, S.D.N.Y.)
Summary
In a letter dated January 22, 2021, Peter Katz, counsel to Muge Ma, asks Judge Richard M. Berman on behalf of the parties to adjourn the telephonic status conference set for January 27, 2021 in United States v. Muge Ma, 20 CR 407 (RMB), Southern District of New York, until the week of March 1, 2021 or thereafter. 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 on-going plea discussions that would obviate the need for a trial. The parties also ask to exclude time under the Speedy Trial Act, Title 18, United States Code, Section 3161(h)(7)(A), and Assistant U.S. Attorney Sagar Ravi consents. The endorsement, dated 1/22/2021, grants the application and adjourns the conference to Wednesday, March 3 at 10:30 AM, with time excluded.
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Full text
Case 1:20-cr-00407-RMB Document 31
32 Filed 01/22/21 Page 1 of 1
January 22, 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 January 27,
2021 until the week of March 1, 2021 or thereafter.
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. Accordingly, in order to allow time for the parties to
complete our negotiations, the parties respectfully request that the January 27, 2020 conference be
adjourned until March 1, 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.
Sincerely,
Application granted. Conference
adjourned to Wednesday. March 3, Peter Katz, Esq.
2021 at 10:30 AM. Time is excluded Counsel to Muge Ma
pursuant to the Speedy Trial Act for the
reasons set forth in this letter.
1/22/2021 1
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