Case 1:19-cr-00870-JMF Document 18 Filed 04/17/20 Page 1 of 2
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`ROTHMAN, SCHNEIDER, SOLOWAY & STERN, LLP
`Attorneys at Law
`100 Lafayette Street, Suite 501
`New York, NY 10013
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`Franklin A. Rothman
`Jeremy Schneider
`Robert A. Soloway
`David Stern
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`Rachel Perillo
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`Tel: (212) 571-5500
`Fax: (212) 571-5500
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`April 14, 2020
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`Re: United States v. Mustapha Raji
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`19 Cr. 870 (JMF)
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`By ECF
`Hon. Jesse M. Furman
`United States District Judge
`Southern District of New York
`40 Foley Square
`New York, New York 10007
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`Dear Judge Furman:
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`I am the attorney for Mustapha Raji, the defendant in the above referenced matter. Due
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`to certain limitations posed by the present COVID-19 pandemic, and the ongoing discovery
`production in this case, I write with the consent of the attorney for the government, Dina
`McCleod, respectfully seeking an extension of the current motion deadlines and an adjournment
`of the status conference that is presently scheduled for May 11, 2020.
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`The discovery that has already been produced in this case is massive, and I have not yet
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`had sufficient time to review it in light of the present circumstances. The government has also
`informed me that it will be producing two additional phone extractions. Additionally, the
`defendant has neither reviewed nor received the discovery already produced. As the Court is
`aware, legal visiting at the Metropolitan Correctional Center, where Mr. Raji is in custody, is
`currently suspended. Some of the discovery materials are subject to a protective order and
`cannot be viewed outside the presence of counsel. Accordingly, additional time is needed to
`review the discovery and to ensure that Mr. Raji has reviewed it as well.
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`The Court has set the following motion schedule: Motions due by May 8, 2020,
`Oppositions due by May 22, 2020, and Replies due by May 29, 2020. Because additional time is
`needed to review discovery and determine whether the defendant will be making motions, I
`respectfully request an extension of the Court’s deadlines to the following proposed dates:
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`Case 1:19-cr-00870-JMF Document 18 Filed 04/17/20 Page 2 of 2
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`Hon. Jesse M. Furman
`April 14, 2020
`Page Two
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`Motions Due: June 26, 2020
`Oppositions Due: July 10, 2020
`Replies Due: July 17, 2020
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`Additionally, for the same reasons discussed above, I respectfully request an adjournment
`of the May 11th status conference and propose an adjournment date of June 20, 2020. The
`defendant consents to the exclusion of speedy trial time.
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`If the Court has any questions regarding this application please contact my office.
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`Respectfully submitted,
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`/s/
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`Jeremy Schneider
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`cc:
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`Dina McCleod (by ECF)
`Assistant United States Attorney
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`Application GRANTED. The schedule suggested by the parties is hereby ADOPTED.
`The pretrial conference is ADJOURNED to June 29, 2020, at 3:30 p.m. Time is
`excluded in the interests of justice to allow the defendant and counsel adequate time to
`review the voluminous discovery and prepare pretrial motions. The Clerk of Court is
`directed to terminate ECF No. 17. SO ORDERED.
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`April 17, 2020
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