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Case 1:19-cr-00490-RMB j7v2espC kjc Document 42 Filed 08/06/19 Page 7 of 10 7 1 MR. WEINBERG: This case certainly meets all of the 2 statutory criteria for complexity and we would agree to that 8 extension, Judge. 4 MS. MOE: Your Honor, may I briefly be heard with 5 respect to the trial date? 6 THE COURT: Oh, sure. You know, it does sound like it 7 is kind of premature, but I'm happy to hear you. It is often 8 the defense that is ahead of the government, or not often, but 9 equally, but here it is the other way around. So if the 10 defense is not ready, it would be my practice to defer to the 11 defense, but I don't know that it is fixed in stone either way. 12 But, sure, am happy to hear you. 13 MS. MOE: Your Honor, by way of background, we had 14 initially proposed to the defense a May trial date. We think 15 that there is a public interest in bringing this case to trial 16 as swiftly as manageable. We understand, given their concerns 17 in wanting to have more time, we proposed a date in June as a 18 compromise position. We understand if the defense has 19 indicated that they need additional tim are sensitive to 20 those concerns. But we do have a concern about the notion of 21 setting a September trial date and that that trial would be 22 preliminary or as a placeholder. Thirteen months is a 23 considerable amount of time for a case of this nature to go to 24 trial; and, again, given the time period of the charged conduct 25 and the length of time that's passed, we do think that there is SOUTHERN D STR (212) CT REPORTERS, 805-0300 DOJ-OGR-00000618