Case 1:18-cr-00693-RMB Document 109 Filed 08/13/19 Page 1 of 2
Case 1:18-cr-00693-RMB Document 108 Filed 08/12/19 Page 1 of 2

U.S. Department of Justice
United States Attorney
Southern District ofNew York
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: vOCUMENT

ELECTRO NI CALLY FILED
DOC #: _ _ _---r_,~- DATE FILED:~i_,_
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August 12, 2019

MEMO ENDORSED

BYECF
The Honorable Richard M. Berman
United States District Judge
Southern District of New York
500 Pearl Street
New York, _N ew York 10007
Re:

The Sl/'vlo J. Mollo But/dins
On~ Saint Andrew 's Pl=
New York, New York.10007

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United States v. Richard Gaffey and Harald Joachim von der Goltz, 18 Cr. 693 (RMB)

Dear Judge Berman:
The Government respectfully submits this letter requesting an adjournment of the trial in
this case. On March 12, 2019, the Court held a status conference in which it set a trial date of
October 28, 2019, along with dates for pretrial submissions and a pretrial conference. At the March
12 status conference, the Government informed the Court that it would be moving for a pretrial
conference under Section 2 of the Classified Information Procedures Act; 18 U.S.C. App. III
1
(' CIPA"); 'and that it was possible that compliance with the procedures set forth in CIPA could
necessitate a delay in the trial date. See Tr. of March 12, 2019 Conf., at 6-7. On July 29, 2019, the
Court held an ex parte pretrial conference pursuant to Section 2 of CIP A. At that time, the
Government informed the Court that due to certain developments that had not been previously
anticipated, additional time would be required to complete the CIP A process. The Court ordered
the Government to meet and confer with the ·defense regarding a new trial date.

 Case 1:18-cr-00693-RMB Document 109 Filed 08/13/19 Page 2 of 2
Case 1:18-cr-00693-RMB Document 108 Filed 08/12/19 Page 2 of 2

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August 6, 2019
Page2

December 1 ___ __
for pretrial submissions, including motions in limine, joint
v, r
eet, and names and places for voir dire.
jury charge
Decembe 23, 2019: D e date for responses to motions in limin~. ItJanuary 6, 2020: Final pretrial conference. O.. I J~(f'O fl-(\-1 CJ''
January 13, 2020: Trial.

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Because the purpose of this requested adjournment is to ensure that the Government
complies with its discovery obligations in accordance with the procedures set forth in CIPA, the
parties jointly submit that the ends of justice served by the granting of such continuance outweigh
the best interests of the public and the defendant in a speedy trial, and request that the Court
accordingly exclude time under 18 U.S.C. 3161(h)(7)(A) and (B), from October 28, 2019, until
January 13, 2020. The Government has met and conferred with defense counsel, who consents to
these requests.
Respectfully submitted,
GEOFFREY S. BERMAN
United States Attorney for the
Southern District of New York

DEBORAH CONNOR
Chief, Money Laundering and Asset Recovery
Section, Criminal Division

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Eun Young Choi and Thane Rehn
Assistant United States Attorneys
(212) 637-2187/2354
Michael Parker and Parker Tobin
Trial Attorneys, Criminal Division
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Defense Counsel (by ECF)