Opinion
No. 3:11-00237
06-21-2012
UNITED STATES OF AMERICA v. OLEKSANDR VYSHNEVSKYY
Judge Trauger
MOTION TO CONTINUE TRIAL AND
ENLARGE PLEA DEADLINE
COMES NOW the Defendant, Oleskandr Vyshnevskyy, by and through his undersigned counsel, and hereby moves this Honorable Court for the entry of an Order (1) continuing the trial from July 10, 2012 to a date no earlier than late August 2012; and, (2) resetting the plea related deadlines consistent with the standard order of this Court. In support hereof, Defendant Vyshnevskyy states as follows:
1. This matter is currently set for trial on July 10, 2012. (Docket Entry 31). This is a first trial setting of this case.
2. Defendant Vyshnevskyy anticipates that, with additional time, this matter will be for plea rather than trial. However, a resolution of this case cannot be reached in the time remaining before the July 10, 2012 trial setting.
3. Currently, Defendant Vyshnevskyy and the government are exploring a potential resolution of this case. However, undersigned counsel is concerned about a disposition determinative aspect of the potential guideline calculation (safety valve) and is seeking input on the issue from the U.S. Probation office. Additionally, undersigned counsel is presently attempting to