`
`ROTHMAN, SCHNEIDER, SOLOWAY & STERN, LLP
`Attorneys at Law
`100 Lafayette Street, Suite 501
`New York, NY 10013
`
`Franklin A. Rothman
`Jeremy Schneider
`Robert A. Soloway
`David Stern
`
`Rachel Perillo
`
`Via ECF & Email
`Hon. 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)
`
`Tel: (212) 571-5500
`Fax: (212) 571-5500
`
`March 4, 2022
`
`Application GRANTED (without happiness). Trial
`is ADJOURNED to September 12, 2022. Time is
`excluded under the Speedy Trial Act between today
`and September 12, 2022, to ensure continuity of
`counsel and allow the parties to prepare for trial.
`The Clerk of Court is directed to terminate ECF
`No. 75. SO ORDERED.
`
`Dear Judge Furman:
`
`March 10, 2022
`
`I am the attorney for Mustapha Raji, the defendant in the above-referenced matter. Trial
`in this case is scheduled for April 26, 2022. This letter is respectfully submitted to inform the
`Court of an unforeseen scheduling conflict and to request, without objection from the
`government, to postpone trial.
`
`I was previously scheduled to begin trial in United States v. Christian Pabon, 18 Cr. 319
`(SHS) on May 16, 2022. Yesterday, I was informed by court order that the Ad Hoc Committee
`on the Resumption of Jury Trials has advanced the Pabon case to May 2, 2022. See 18 Cr. 319
`(SHS) (Dkt. 481). Pabon is a murder racketeering case from 2018 and the defendant is
`incarcerated. Because I am unable to try both of these cases at the same time, it is respectfully
`requested that trial in the instant matter be postponed. I have conferred with the government, by
`AUSA Dina McLeod, and if the Court grants this application, the parties are available to try this
`case at any time from June 28 through July 22, 2022, or August 29 through September 23,
`2022. Mr. Raji consents to the exclusion of time under the Speedy Trial Act in order to continue
`plea negotiations as well as trial preparation.
`
`If the Court has any questions regarding this application, please do not hesitate to contact
`
`me.
`
`cc:
`
`AUSA Dina McLleod (By ECF & Email)
`
`Respectfully submitted,
`/s/
`Jeremy Schneider
`
`
`
`
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