10-20-21 - Joint MOTION to Continue October 28, 2021 Status Hearing for Sixty Days by JOHN EARLE SULLIVAN.txt

1 
                                  UNITED STATES DISTRICT COURT  
               FOR THE DISTRICT OF COLUMBIA  
 
UNITED STATES OF AMERICA  
 
 V.      Case No.: 21 -cr-78 (EGS)  
 
 
JOHN SULLIVAN  
 
         JOINT MOTION TO CONTINUE OC TOBER 28, STATUS HEARING  
 
 The parties  hereby respectfully request the Court to continue the 
October 28, 2021 status hearing  for approximately 60 days . In support 
thereof, the pa rties set forth as follows:  
 1. This case involves a multi -count indictment with a vast amount of 
discovery. The process of receiving and reviewing  the discovery is 
proceeding in an orderly and cooperative fashion  
 2. There have recently  been very large files of di scovery produced 
consisting of , among other items , thousa nds of hours of videotapes. The  
files require a very signi ficant amount of time to be reviewed and evaluated.  
 3. While the process of discovery review is on -going , the parties do 
not presently  have additional informati on to present to the Court at a formal 
status hearing.   Case 1:21-cr-00078-EGS   Document 51   Filed 10/20/21   Page 1 of 42 
  4. Counsel for th e respective parti es have conferred and believe that 
an approximately 60 -day continua nce of the October 28, 2021 status 
hearing is the best way in which to proceed.  
 5. The parties rel y upon the discretionary powers of this H onorable 
Court in seek ing the r elief requested here in. 
 WHEREFORE, the foreg oing considered, the parti es pray this 
Honorable Court to continue the Octob er 28, 2021 statu s hearing  for 
approximately 60 days . 
     
       Respectfully submitted , 
 
       _______/s/_______________  
       Steven R. Kiersh #323329  
       5335 Wisconsin Avenue, N.W.  
       Suite 440  
       Washington, D.C. 20015  
       (202) 347 -0200  
 
       _______ /s/__________________  
       Candice  C. Wong  #990903  
       Assistant U.S. Attorney  
       555 4th Street, N.W.  
       Washington, D.C. 20530  
       (202) 252 -7849  
  
 
 
                      
                                      
 
 Case 1:21-cr-00078-EGS   Document 51   Filed 10/20/21   Page 2 of 43 
  
 
    CERTIFICATE OF SERVICE  
 
 I HEREBY CERTIFY that a true and accurate copy of the foregoing 
was served, via the Court’s electronic filing system, on this 20th day of 
October , 2021 upon all counsel of record, including Candice Wong, 
Esquire, Assistant U.S Attorney.   
 
               
      ______ /s/____________________  
      Steven R. Kiersh  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 Case 1:21-cr-00078-EGS   Document 51   Filed 10/20/21   Page 3 of 44 
  Case 1:21-cr-00078-EGS   Document 51   Filed 10/20/21   Page 4 of 4