`U.S. Department of Justice
`
`United States Attorney
`Southern District of New York
`
`The Silvio J. Mollo Building
`One Saint Andrew’s Plaza
`New York, New York 10007
`
`October 14, 2020
`
`[Type text]
`
`BY ECF AND EMAIL
`
`The Honorable Jesse M. Furman
`United States District Judge
`Southern District of New York
`40 Foley Square
`New York, New York 10007
`
`Re: United States v. Mustapha Raji, 19 Cr. 870 (JMF)
`
`Dear Judge Furman:
`
`The Government and the defendant write jointly in response to the Court’s direction that
`the parties submit a letter indicating our views on whether the proceeding scheduled for October
`29, 2020 should be held. (See Dkt. Entry No. 44).
`
`The parties request that the proceeding scheduled for October 29, 2020 be adjourned to a
`date in mid-January 2021. Due to the defendant’s residence in Florida, and the defendant’s
`ongoing medical issues—which have required some hospitalization—the defendant and defense
`counsel have not been able to adequately confer regarding a possible plea or motions.
`
`Should the Court wish to hold a proceeding this month, the parties request a virtual pretrial
`conference, so that the defendant need not travel to New York and risk additional exposure to the
`coronavirus. The defendant waives his appearance at either an in-person proceeding or a virtual
`proceeding. The parties are available at the following dates and times: October 27th after 12:00
`p.m.; October 28th after 3:30 p.m.; October 29th at any time; October 30th before 12:00 p.m. or after
`3:00 p.m.
`
`If the Court adjourns the pretrial conference to a date in mid-January 2021, the parties
`respectfully request that the Court exclude time under the Speedy Trial Act from October 29, 2020
`to the next pretrial conference date, so that the defendant and his counsel have adequate time to
`confer regarding a possible pretrial disposition and/or possible motions.
`The Court will hold a teleconference with the attorneys
`on October 27, 2020, at 2:15 p.m. To access the
`conference, counsel should call 888-363-4749 and use
`access code 5421540#. (Members of the press and
`public may call the same number, but will not be
`permitted to speak during the conference.) Counsel
`By:
`should be sure to consult the Court's Emergency
`Individual Rules and Practices, available on the
`Court's website, and comply with the rules regarding
`conferences. The Clerk of Court is directed to
`terminate Doc. #45. SO ORDERED.
`
`Respectfully submitted,
`
`AUDREY STRAUSS
`Acting United States Attorney
`
`Dina McLeod/Eun Young Choi
`Assistant United States Attorneys
`(212) 637-1040/ -2187
`
`October 16, 2020
`
`
`
`

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