`Case 1:18-cr-00905-L TS Document 85 Filed 11115119 Page 1of1
`
`RICHARD PALMA
`ATTORNEY AT LAW
`11 PARK PLACE - SUITE 1715
`NEW YORK, NEW YORK 10007
`
`MEMBER OF THE BAR
`NEW YORK & FLORIDA
`
`ECF filed
`
`Honorable Laura Taylor Swain
`United States District Judge
`U.S. District Court for S.D.N.Y.
`500 Pearl Street
`New York, N.Y. 10007
`
`TEL. (212) 686-8111
`FAX. (212) 202-7800
`E-MAIL: rpalma177@gmail.com
`
`November 15, 2019
`
`~J1EMO ENDORSED
`
`Re: U.S. v. Wang, 18 Cr. 905 (LTW)
`Without objection by the Government, this is a joint request on behalf of
`Defendants Xiao Wang & Jiau Feng Wu to continue the November 19th
`Status Conference to an afternoon of the week of December 16th •
`
`Dear Judge Swain:
`
`As attorneys of record for Messrs. Jian Feng Wu and Xiao Wang, Mr. Christopher
`Madiou and I respectfully request that our November 19th court appearances before Your Honor
`be continued to the week of December 16th in the afternoon. The Government does not oppose
`this joint defense request. I can represent to the Court on behalf of Mr. Madiou and myself that
`the parties are actively involved in plea negotiations with the Government and that we anticipate
`a resolution of our respective cases without a trial by the next court appearance. Finally, the
`parties content to the exclusion of time under the Speedy Trial Act, 18 U.S.C. § 3161.
`
`I am available immediately to Your Honor should the Court have questions about this
`request. My cellular phone number is (917) 751-5754.
`
`Thank you.
`
`j'HE. APPLICATION IS GRANTED THE CONFERENCE IS~~ -fu
`\.,}_ 11}t ty.T _1_:_~ IN COURTROOM I 7C. THE ' URT FINDS PURSUANT TO 18
`1J -S.C. §3161 (11)(7)(A) THAT THE ENDS OF JUSTICE SERVED BY AN EXCLUSION OF THE TIME
`FROM TODA y's DATE THROUGH~ .l}f _60UTWEIGH THE BEST INTERESTS Of THE PUBLIC AND
`rHE DEFENDANT IN A SPEEDY TRIAL FOR THE REASONS STATED ABOVE SO ORDERED.
`
`~cilill'i
`1~~6R-SWAIN, USDJ
`
`Richard Palma
`
`chard Palma (Bar No. rp 4441)
`
`- ~spectfully submitted,
`
`RICHARD PALMA
`ATTORNEY AT LAW
`
`
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