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Case 1:19-cr-00830-AT Document 26 Filed 02/10/20 Page3of15 3 k1lu2NoeC kjc 1 own investigation, which can't really fully get started until 2 we appreciate what information has already been provided. 3 That's really the crux of the reason. 4 Now, I noted in the government's opposition, although 5 they agree that some adjournment is warranted, I guess the 6 issue is of how long the adjournment should be. The defense is 7 in the best position to assess how much time we need to perform 8 our important function on behalf of our clients. I say that 9 because we are not making a request for the purpose of simply 10 delaying the proceedings. We are doing it because it is 11 actually necessary to accomplish our goals as counsel. 12 Also, which I did not reference in my letter, is it 13 also takes into account my trial schedule, at least why my 14 request was. Last week, I was scheduled to start a trial 15 before Judge Ramos in 40 Foley Square in July. And part of 16 what I discussed with Judge Ramos in setting that trial date 17 was that I knew that this trial may need to be accommodated in 18 some way. He selected July 20 for that date mostly because of 19 the court's availability at that time. That's also part of the 20 reason. And in that particular case, my client's been 21 incarcerated for almost two years. He is facing a mandatory 22 life sentence. So I do need to spend some of my time getting 23 ready for that as well, and I expect that to be our trial date. 24 THE COURT: What's the date? 25 MR. FOY: What's the date? SOUTH ERN DIS TRICT REPORTERS, P.C. (2 12) 805-0300 DOJ-OGR- 00022006