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1:21-cr-00161-CM
2021 | Cited 0 times | S.D. New York | May 19, 2021
DOCUMENT
FILEµ \ ' • 5\l~ )o«H
Pla=a Document 39 Filed in NYSD on 05/17/2021 Page 1 of 2
BYECF
USDCSDNY ELECTRONICALLY DOC#: DATEFILED:
The Honorable Colleen McMahon United States District Judge Southern District of New York 500 Pearl Street New York, New York 10007 Re :
U.S. Department of Justice
The Silvio J. Mollo Building One Saini Andrew ·s Ne w York, New Yo rk 10007
A status conference is scheduled in the above-captioned matter for May 19, 2021 . The Government writes respectfully to request an approximately 30-day adjournment of the conference. The Government and defense counsel for both defendants have been engaged in productive discussions regarding possible pretrial resolution. With respect to defendant Hierro Clase, the parties have reached an agreement for a pretrial disposition and are scheduling a change of-plea conference before the Magistrate Judge. With respect to defendant Hierro-Belen, negotiations towards a possible pretrial resolution have progressed and the parties hope to reach an agreement within the next approximately 30 days. The adjournment is requested to permit parties additional time to complete the change-of-plea proceeding before the Magistrate Judge and for the parties to continue discussions and for defense counsel to advise the defendants regarding possible pretrial disposition, which communications are hampered in part by the limitations and restrictions on such communications caused by the COVID-19 pandemic.
In the event that the Court grants the requested adjournment, the Government respectfully requests that the Court exclude time under the Speedy Trial Act, from May 19, 2021 until such date as the conference is rescheduled for the reasons stated above. The Government submits that the ends of justice served by the continuance outweigh the best interests of the public and the defendants in a speedy trial. See 18 U .S .C. § 3161 (h)(7)(A).
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Page 2 I have communicated with defense counsel, Mr. Sp*rn for defendant Hierro-Clase and Mr. Silveri for defendant Hierro-Belen, who both consent to the adjournment and exclusion of time.
Respectfully submitted, AUDREY STRAUSS United States Attorney By:
cc: Michael H. Sp*rn, Esq. (via ECF)
Jon Silveri, Esq. (via ECF)
Brett M. Kalikow Assistant United States Attorney (212) 63 7-2220
DOCUMENT
FILEµ \ ' • 5\l~ )o«H
Pla=a Document 39 Filed in NYSD on 05/17/2021 Page 1 of 2
BYECF
USDCSDNY ELECTRONICALLY DOC#: DATEFILED:
The Honorable Colleen McMahon United States District Judge Southern District of New York 500 Pearl Street New York, New York 10007 Re :
U.S. Department of Justice
The Silvio J. Mollo Building One Saini Andrew ·s Ne w York, New Yo rk 10007
A status conference is scheduled in the above-captioned matter for May 19, 2021 . The Government writes respectfully to request an approximately 30-day adjournment of the conference. The Government and defense counsel for both defendants have been engaged in productive discussions regarding possible pretrial resolution. With respect to defendant Hierro Clase, the parties have reached an agreement for a pretrial disposition and are scheduling a change of-plea conference before the Magistrate Judge. With respect to defendant Hierro-Belen, negotiations towards a possible pretrial resolution have progressed and the parties hope to reach an agreement within the next approximately 30 days. The adjournment is requested to permit parties additional time to complete the change-of-plea proceeding before the Magistrate Judge and for the parties to continue discussions and for defense counsel to advise the defendants regarding possible pretrial disposition, which communications are hampered in part by the limitations and restrictions on such communications caused by the COVID-19 pandemic.
In the event that the Court grants the requested adjournment, the Government respectfully requests that the Court exclude time under the Speedy Trial Act, from May 19, 2021 until such date as the conference is rescheduled for the reasons stated above. The Government submits that the ends of justice served by the continuance outweigh the best interests of the public and the defendants in a speedy trial. See 18 U .S .C. § 3161 (h)(7)(A).
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Page 2 I have communicated with defense counsel, Mr. Sp*rn for defendant Hierro-Clase and Mr. Silveri for defendant Hierro-Belen, who both consent to the adjournment and exclusion of time.
Respectfully submitted, AUDREY STRAUSS United States Attorney By:
cc: Michael H. Sp*rn, Esq. (via ECF)
Jon Silveri, Esq. (via ECF)
Brett M. Kalikow Assistant United States Attorney (212) 63 7-2220
