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United States’s Unopposed Motion to Continue Status Conference — No. 1:21-cr-00625 (Dkt. 24, D.D.C.)

Summary

United States's Unopposed Motion to Continue Status Conference, Document 24 in No. 21-CR-625 (APM) in the District of Columbia, filed 05/05/22 and dated May 5, 2022. The government asks the Court to move the status conference to June 29, 2022 at 9 AM and to exclude the intervening time under the Speedy Trial Act, 18 U.S.C. 3161, because undersigned counsel will be out of the country on June 23, 2022, the date previously set, returning June 27, 2022. The motion recounts that a grand jury returned a one-count bank fraud indictment under 18 U.S.C. 1344 on October 12, 2021, that the defendant was arraigned on October 20, 2021, and that status conferences were held on January 20, 2022 and March 25, 2022 with time excluded at each stage. The defendant does not object.

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“United States’s Unopposed Motion to Continue Status Conference — No. 1:21-cr-00625 (Dkt. 24, D.D.C.).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/united-states-s-unopposed-motion-to-continue-status-conference-no-1-21-8faf1b2e30/, SHA-256 4af1067bc09582613c3ce4c4cb3fff78753653eb502eee6ec2eab397133c9692.

Full text

            Case 1:21-cr-00625-APM Document 24 Filed 05/05/22 Page 1 of 2




                            UNITED STATES DISTRICT COURT
                            FOR THE DISTRICT OF COLUMBIA




 UNITED STATES OF AMERICA

        v.                                            No. 21-CR-625 (APM)

 ROBERTO ADAMS,

                        Defendant.




                        UNITED STATES’S UNOPPOSED MOTION
                         TO CONTINUE STATUS CONFERENCE


       The United States of America by and through its attorney, the United States Attorney for

the District of Columbia, requests that the Court continue the status conference in this matter until

June 29, 2022 at 9 AM, and that the Court exclude the time until the next status conference date

from the calculations under the Speedy Trial Act. 18 U.S.C. § 3161. The Defendant does not

oppose this motion. In support of this request, the Government notes the following:

       1.       On October 12, 2021, a grand jury returned a one-count indictment charging the

Defendant with Bank Fraud, in violation of Title 18, United States Code, Section 1344. (Dkt. 8)

       2.       On October 20, 2021, the Defendant was arraigned on the indictment, a status

conference was set for January 20, 2022, and the Court excluded time between October 20, 2021

and January 20, 2022 for purposes of the Speedy Trial Act.

       3.       On January 20, 2022, the Court held a status conference, a status conference was

set for March 25, 2022, and the Court excluded time between January 20, 2022 and March 25,

2022 for purposes of the Speedy Trial Act.
            Case 1:21-cr-00625-APM Document 24 Filed 05/05/22 Page 2 of 2




       4.        On March 25, 2022, the Court held a status conference, a status conference was set

for June 23, 2022, and the Court excluded time between March 25, 2022 and June 23, 2022 for

purposes of the Speedy Trial Act.

       5.        Undersigned counsel will be out of the country on June 23, 2022 and will return on

June 27, 2022.

       6.        The Government asks that Court reschedule the status conference for June 29, 2022

at 9 AM and excludes time under the Speedy Trial Act because “the ends of justice served by

taking such action outweigh the best interest of the public and the defendant in a speedy trial.” 18

U.S.C. § 3161(h)(7)(A). The Defendant does not object to these requests.

       WHEREFORE, the Government requests—with no objection from the defense—that the

Court continue the status conference in this matter until June 29, 2022 at 9 AM, and that the Court

excludes time between today and the hearing date from calculations under the Speedy Trial Act.

                                              Respectfully submitted,
                                              MATTHEW M. GRAVES
                                              United States Attorney



                                       By:    ___________________________________
                                              Joshua S. Rothstein
                                              Assistant United States Attorney
                                              N.Y. Bar Number 4453759
                                              601 D Street, N.W.
                                              Washington, D.C. 20539
                                              Office: 202-252-7164
                                              Joshua.Rothstein@usdoj.gov
May 5, 2022




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