joe white court motion citing settlement discussions
TRANSCRIPT
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IN THE UNITED STATES DISTRICT COURTFOR THE EASTERN DISTRICT OF TEXAS
TYLER DIVISION
UNITED STATES OF AMERICA
VS. CASE NO. 6:14cr5 (Judge Michael H. Schneider)
JOE WHITE
WHITES UNOPPOSED MOTION FOR CONTINUANCE
1. This case arises from Whites involvement with several hospitals that
received monetary incentives form the Medicare & Medicaid Electronic Health
Record Incentive Programs.
2. White is charged in a two-count indictment. Count one alleges that he
made a false statement. And count two charges him with aggravated identity theft.1 2
3. Whites matter was assigned to this Court because of the related case
styled United States v. Tariq Mahmood, M.D. (Case No. 6:13cr32). That case is set
for trial on May 12, 2014.
4. Whites case is set on April 7, 2014, for a pretrial conference and trial
scheduling.
/ 18 U.S.C. 1001(a)(2) & (a)(3).1
/ 18 U.S.C. 1028A(a)(1).2
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5. The Government and White have been diligently working in a
cooperative fashion since this cases inception. White is currently reviewing the
discovery that the Government provided soon after Whites indictment.
6. Both parties have been and are still entertaining settlement options.
But White simply has not had enough time to digest the discovery and contemplate
his own investigative avenues.
7. The Government has likewise been busy preparing for the Mahmood
trial.
8. White therefore asks that his case be continued for 60-90 days, so that
he can be adequately prepared to address any pretrial matters that may arise.
9. The prosecutor in charge of this case, Nathaniel Kummerfeld, is not
opposed to this request.
Respectfully submitted,
KETTERMAN HEDLESTEN & AMANN, PLLC
By: /s/ Colin B. Amann COLIN B. AMANN Texas Bar No. 01138100 1004 Prairie, Suite 300 Houston, TX 77002 713-652-2003 (Voice) 713-652-2002 (Fax) [email protected]
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CERTIFICATE OF CONFERENCE
I spoke with the prosecutor in charge of this case, Nathaniel Kummerfeld, and
was told that he is not opposed to this request.
/s/ Colin B. Amann
CERTIFICATE OF SERVICE
A copy of Whites Unopposed Motion for Continuance was sent to the
following person(s) by the means indicated on March 25, 2014:
E-Mail: [email protected] KummerfeldAssistant U.S. AttorneyEastern District of TexasTyler Division
/s/ Colin B. Amann
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