`U.S. Department of Justice
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`United States Attorney
`Southern District of New York
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`The Silvio J. Mollo Building
`One Saint Andrew’s Plaza
`New York, New York 10007
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`December 11, 2020
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`[Type text]
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`BY ECF
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`The Honorable George B. Daniels
`United States District Judge
`Southern District of New York
`500 Pearl Street
`New York, New York 10007
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`Re: United States v. Maxim Suverin
`18 Cr. 509 (GBD)
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`Dear Judge Daniels,
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`Defendant Maxim Suverin was arrested on June 30, 2018 (Dkt. No. 2) and has been
`detained since his arrest. On February 5, 2020, the Court set a trial date for May 11, 2020. In light
`of the COVID-19 pandemic, the Court subsequently canceled that trial date. Suverin remains the
`only arrested defendant in this case who has not yet pleaded guilty. The Government had
`anticipated that Suverin would plead guilty on December 16, 2020. However, defense counsel
`recently informed the Government that the defendant is not yet prepared to plead guilty.
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`As a result, the Government respectfully requests that the Court cancel the December 16,
`2020 conference and set a trial date for Suverin at the earliest possible date. The Government has
`asked defense counsel to provide any trial conflicts over the next six months, but has not received
`a response. The Government is available to try this case at any time. The Government further
`requests that the Court exclude time under the Speedy Trial Act through the trial date. Such an
`exclusion of time would be in the interests of justice as it would allow the parties time to prepare
`for trial. See 18 U.S.C. § 3161(h)(7)(A).
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`Respectfully submitted,
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`AUDREY STRAUSS
`Acting United States Attorney
`Southern District of New York
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`/s/___________________________
`Matthew J.C. Hellman
`Emily A. Johnson
`Daniel G. Nessim
`Assistant United States Attorneys
`(212) 637-2278/-2409/-2486
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