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Motion to Continue Trial Date — No. 1:24-cr-00323 (Dkt. 75, D.D.C.)

Summary

A Motion to Continue Trial Date, Document 75 filed January 26, 2026 in the District of Columbia (Case 1:24-cr-00323-CRC), United States v. Jose Biaou, filed by Timothy D. Belevetz of Ice Miller LLP. The defendant asks to continue the February 9, 2026 trial date by three months to May 11, 2026. His prior counsel from Quinn Emanuel Urquhart & Sullivan LLP moved to withdraw on December 31, 2025 and the court granted the motions on January 15, 2026, and he has met the Federal Public Defender for only a few hours. The new counsel was retained solely to file this motion and to allow time to consider dispositive motions, and expects to enter an unlimited appearance if the trial is continued.

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Cite this document

“Motion to Continue Trial Date — No. 1:24-cr-00323 (Dkt. 75, D.D.C.).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/motion-to-continue-trial-date-no-1-24-cr-00323-dkt-75-d-d-c-617f401cd7/, SHA-256 19e2c205a7d8531bc452e44e4bcc5d0732fa990816055f26372d36dcfe31b313.

Full text

         Case 1:24-cr-00323-CRC          Document 75        Filed 01/26/26      Page 1 of 3




                             UNITED STATES DISTRICT COURT
                             FOR THE DISTRICT OF COLUMBIA


 UNITED STATES OF AMERICA,


 v.

                                                       Case No. 1:24-cr-323
 JOSE BIAOU,


                 Defendant.




                           MOTION TO CONTINUE TRIAL DATE

         Defendant Jose Biaou, through undersigned counsel, respectfully moves this Honorable

Court to continue the February 9, 2026, trial date for the following reasons:

      1) Defendant’s prior counsel from Quinn Emanuel Urquhart & Sullivan LLP moved to

         withdraw from the case on December 31, 2025. See ECF Nos. 42-44. This Court granted

         counsel’s motions to withdraw on January 15, 2026.

      2) While Defendant has had access throughout this matter to the Federal Public Defender,

         who continues to represent him, Defendant has not had the opportunity to meet and

         strategize with the Federal Public Defender for more than a few hours.

      3) Defendant desires to engage the undersigned counsel to represent him in this matter. For

         the time-being, the undersigned counsel has been retained solely to file this Motion to

         Continue the Trial Date to provide time to consider filing dispositive motions that

         Defendant previously has not had the opportunity to file.
   Case 1:24-cr-00323-CRC          Document 75        Filed 01/26/26      Page 2 of 3




4) Defendant respectfully requests a continuance of three months to May 11, 2026 so that

   the undersigned counsel may evaluate and file, if appropriate, such dispositive motions

   and prepare for trial.

5) Should the Court continue the trial date, the undersigned counsel anticipates entering an

   unlimited appearance in this case.



                                                Respectfully submitted,

                                         By:          /s/
                                                Timothy D. Belevetz
                                                Ice Miller LLP
                                                200 Massachusetts Avenue, N.W., Suite 400
                                                Washington, DC 20001
                                                Tel: (202) 572-1605
                                                Fax: (202) 824-8667
                                                timothy.belevetz@icemiller.com

                                                Attorney for Defendant Jose Biaou




                                            2
       Case 1:24-cr-00323-CRC          Document 75       Filed 01/26/26      Page 3 of 3




                                CERTIFICATE OF SERVICE

        I certify that on this 26th day of January 2026, I caused the foregoing to be filed
electronically using the Court’s CM/ECF system, which sends a notification of such filing to all
counsel of record.


                                                           /s/
                                                    Timothy D. Belevetz
                                                    Ice Miller LLP
                                                    200 Massachusetts Avenue, N.W., Suite 400
                                                    Washington, DC 20001
                                                    Tel: (202) 572-1605
                                                    Fax: (202) 824-8667
                                                    timothy.belevetz@icemiller.com

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