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Letter to Judge Dearie Re: United States v. Keily Nunez, et al., Criminal Docket No. 21-496 (RJD) (Dkt. 91, E.D.N.Y.)

Summary

In this July 1, 2022 letter to Judge Raymond J. Dearie of the Eastern District of New York, the government gives an update on plea negotiations, as directed by the Court's March 3, 2022 order, in United States v. Keily Nunez, et al. (No. 21-496) and United States v. Ramon Osvaldo Pena (No. 21-560). It says the government remains in plea discussions with all remaining defendants and that the parties are hopeful both cases will be resolved short of trial. The government says it is nonetheless preparing for trial, currently scheduled to begin following jury selection on October 5, 2022, and will be prepared to proceed then if necessary. The letter is signed for United States Attorney Breon Peace by Trial Attorney Patrick J. Campbell of the Justice Department's Criminal Division, Fraud Section, with Assistant U.S. Attorney Garen S. Marshall.

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Full text

                                                     U.S. Department of Justice


                                                     United States Attorney
                                                     Eastern District of New York
PJC/GSM                                              271 Cadman Plaza East
F. #2021R00254                                       Brooklyn, New York 11201



                                                     July 1, 2022

By Email and ECF

The Honorable Raymond J. Dearie
United States District Court
Eastern District of New York
225 Cadman Plaza East
Brooklyn, New York 11201

               Re:    United States v. Keily Nunez, et al.
                      Criminal Docket No. 21-496 (RJD)

                      United States v. Ramon Osvaldo Pena
                      Criminal Docket No. 21-560 (RJD)

Dear Judge Dearie:

                The government writes pursuant to the Court’s March 3, 2022 order to provide an
update regarding plea negotiations. The government remains in plea discussions with all
remaining defendants and the parties are hopeful that the above-referenced cases will be resolved
short of trial. Nonetheless, the government is preparing for trial, which is currently scheduled to
begin following jury selection on October 5, 2022, and the government will be prepared to
proceed on that date if necessary.
                The government is available should Your Honor have any questions regarding the
status of these cases.



                                                  Respectfully submitted,

                                                  BREON PEACE
                                                  United States Attorney

                                           By:    /s/Patrick J. Campbell
                                                  Patrick J. Campbell
                                                  Trial Attorney
                                                  Criminal Division, Fraud Section
                                                  United States Department of Justice
                                                  (718) 254-6366

                                                  Garen S. Marshall
                                                  Assistant United States Attorney
                                                  (718) 254-6569

cc:    Clerk of Court (RJD) (by email and ECF)
       All counsel of record (ECF)




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