Case 1:18-cr-00218-TSC Document 54 Filed 11/16/18 Page 1 of 3 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA UNITED STATES OF AMERICA v. MARIIA BUTINA, also known as MARIA BUTINA, Defendant. : : : : : : : : : : Criminal Case: 18-218 (TSC) Joint Motion to Continue Status Conference The United States of America, by and through its attorney, the United States Attorney for the District of Columbia, and defendant Mariia Butina, also known as Maria Butina, through her counsel, Robert Driscoll and Alfred Carry, Esqs., respectfully request that the Court continue the status conference in this matter (including the motions-briefing schedule), presently set for December 6, 2018, for approximately two weeks. In support of this motion, the parties state that they continue to engage, as they did prior to yesterday’s defense filing, in negotiations regarding a potential resolution of this matter and that those negotiations would be potentially hindered by simultaneously engaging in motions practice. The parties further agree that to make the best and most efficient use of the Court’s time and resources to decide any motions in the event those negotiations are unsuccessful, it would be prudent to continue the upcoming hearing and its accompanying motions schedule for approximately two weeks. If the Court grants this motion, the defendant will withdraw the motion and accompanying documents she filed yesterday [ECF No. 52], without prejudice to refiling within any motions hearing the Court sets. The parties thus jointly request that the Court vacate the current motions schedule and motions hearing date; reset this case for a status conference to take place on December 18, or 19, 1 Case 1:18-cr-00218-TSC Document 54 Filed 11/16/18 Page 2 of 3 2018, if either of those dates are convenient for the Court. The parties also jointly request that the present motions schedule be set back by two weeks. The Court should thus direct the defense to file any dispositive motions on or before November 30, 2016. Any government responses would be due on or before December 14, 2018, and any defense reply would be due on or before December 17, 2018. The parties also jointly request that the Court continue to exclude time under the Speedy Trial Act between now and the next date set. The defendant, through counsel, does not object to this request. For the reasons stated in previous hearings, the parties request that the Court find that this period of delay serves the ends of justice, and that those ends outweigh the best interest of the public and the defendant in a speedy trial. See 18 U.S.C. § 3161(h)(7)(A) & (B)(ii). Respectfully submitted, /s/ Robert N. Driscoll________ Robert N. Driscoll (DC Bar No. 486451) JESSIE K. LIU UNITED STATES ATTORNEY D.C. Bar Number 472845 /s/ Alfred D. Carry___________ Alfred D. Carry (DC Bar No. 1011877) By:___________/s/____________ ERIK M. KENERSON THOMAS N. SAUNDERS Assistant United States Attorneys Ohio Bar Number 82960 (Kenerson) N.Y. Bar Number 4876975 (Saunders) 555 Fourth Street, N.W. Washington, D.C. 20530 Telephone: 202-252-7201 Email: Erik.Kenerson@usdoj.gov McGlinchey Stafford PLLC 1275 Pennsylvania Avenue NW, Suite 420 Washington, DC 20004 Phone: (202) 802-9999 Fax: (202) 403-3870 rdriscoll@mcglinchey.com acarry@mcglinchey.com Counsel for Defendant /s/_______________ WILLIAM A. MACKIE Trial Attorney, National Security Division N.C. Bar Number 13816 950 Pennsylvania Avenue, N.W. Washington, D.C. 20530 Telephone: 202-233-2122 Email: Will.Mackie@usdoj.gov 2 Case Document 54 Filed 11/16/18 Page 3 of 3 Case 1:18-cr-00218-TSC Document 54-1 Filed 11/16/18 Page 1 of 2 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA UNITED STATES OF AMERICA v. MARIIA BUTINA, also known as MARIA BUTINA, Defendant. : : : : : : : : : : Criminal Case: 18-218 (TSC) ORDER Upon consideration of the parties’ Joint Motion to Continue Status Conference, ECF No. ___, it is hereby ORDERED that the Status Conference and Motions Schedule, which were set at a status by Order of this Court, ECF No. 47, are hereby VACATED. It is FURTHER ORDERED that the parties shall appear for a status conference before this Court on ________________________ at ________. It is FURTHER ORDERED that any dispositive motions are due by November 30, 2018. Any responses are December 14, 2018, and any replies are due by December 17, 2018. The Court finds, based on the representations in the parties’ Joint Motion to Continue Status Hearing, that the defendant’s Motion to Dismiss or Compel Election Between Multiplicitous Counts, ECF No. 52 and related documents, is WITHDRAWN WITHOUT PREJUDICE to refiling consistent with the dates above. Case 1:18-cr-00218-TSC Document 54-1 Filed 11/16/18 Page 2 of 2 FURTHER ORDERED that time between the date of this Order and ____________________ shall be excluded from calculation under the Speedy Trial Act, 18 U.S.C. § 3161. The parties are engaged in negotiations about a potential pretrial resolution of this matter. For that reason and the reasons stated at the hearing on September 10, 2018, including the complex nature of this case the Court finds that the ends of justice served by this continuance outweigh the best interests of the public and the defendant in a speedy trial. See 18 U.S.C. § 3161(h)(7)(A) & (B)(ii). SO ORDERED. Date: November ___, 2018 _________________________________ The Honorable Tanya S. Chutkan United States District Judge