MOTION TO CONTINUE TRIAL

The defendant, *, by undersigned counsel, moves the Court to continue the trial of this matter to the Court's December trial term for the following reasons:

1. In all likelihood, Mr.* will be entering a guilty plea, thereby eliminating the need for a trial. Before a plea can be entered, however, it is necessary that Mr.* provide a proffer to see if his assistance merits the dismissal of Count Six of the Indictment, which charges him under 18 U.S.C. § 924(c).

2. If the defendant provides a satisfactory proffer, approval for dismissal of the 924(c) count must be sought through the United States Attorney, Mr. Wilson. As a practical matter, it may take several weeks for a decision to be made on dismissal of the 924(c) count.

3. By this motion, it is requested that the Court continue this case to the December trial term in order to allow time for the plea negotiations described above.

4. By the filing of this motion, Mr.* waives his right to a speedy trial.

5. Ronald Jennings for the United States, John Cascone for Mr. Janvier, and Lisa Call for Mr. Henry have authorized me to represent to the Court that they do not oppose this motion.

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