DOJ-OGR-00000618.pdf

--- Page 1 --- **Document 42** **Case 1:19-cr-00490-RMB** **j7v2espC kjc** **MR. WEINBERG:** This case certainly meets all of the statutory criteria for complexity and we would agree to that extension, Judge. **MS. MOE:** Your Honor, may I briefly be heard with respect to the trial date? **THE COURT:** Oh, sure. You know, it does sound like it is kind of premature, but I'm happy to hear you. It is often the defense that is ahead of the government, or not often, but equally, but here it is the other way around. So if the defense is not ready, it would be my practice to defer to the defense, but I don't know that it is fixed in stone either way. But, sure, I am happy to hear you. **MS. MOE:** Your Honor, by way of background, we had initially proposed to the defense a May trial date. We think that there is a public interest in bringing this case to trial as swiftly as manageable. We understand, given their concerns in wanting to have more time, we proposed a date in June as a compromise position. We understand if the defense has indicated that they need additional time. We are sensitive to those concerns. But we do have a concern about the notion of setting a September trial date and that that trial would be preliminary or as a placeholder. Thirteen months is a considerable amount of time for a case of this nature to go to trial; and, again, given the time period of the charged conduct and the length of time that's passed, we do think that there is **SOUTHERN DISTRICT REPORTERS, P.C.** **(212) 805-0300** **DOJ-OGR-00000618** **Page 7 of 10**