UNITED STATES DISTRICT COURT OF RHODE ISLAND - WPRI.com

Case 1:11-cr-00004-S -DLM Document 76 Filed 06/22/11 Page 1 of 2 PageID #: 477
UNITED STATES DISTRICT COURT OF
RHODE ISLAND
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UNITED STATES OF AMERICA
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THOMAS IAFRATE
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ASSENTED TO MOTION TO CONTINUE STATUS CONFERENCE AND EXCLUDE
CERTAIN TIME UNDER THE SPEEDY TRIAL ACT
Defendant, Thomas Iafrate, by and through his attorney, Kevin B. Salvaggio,
Esquire, move this Honorable Court to continue the Status Conference in this case
for a period of thirty (30) days and exclude this thirty (30) day period from the
seventy-­‐day (70) period from the date of the information or indictment within
which trial must commence pursuant to 18 U.S.C. S3161(c)(1). As grounds to
support his Motion Defendant states as follows:
1. That Defendant’s counsel is in possession of a plea agreement provided by
Assistant United States Attorney William Ferland.

Case 1:11-cr-00004-S -DLM Document 76 Filed 06/22/11 Page 2 of 2 PageID #: 478
2. That Defendant’s counsel needs this thirty-­‐day (30) period to review and
discuss this plea agreement with the Defendant.
3. That Defendant’s counsel has spoken with Assistant United States Attorney
William Ferland concerning this matter, and he assented to this Motion.
Accordingly, the ends of justice will be served by continuing the status
conference and excluding the afore-­‐mentioned time period, and such ends of justice
outweigh the interest of the Defendant and the public in a speedy trial. A Proposed
Order will be submitted to the Court.
Thomas Iafrate,
By his Attorney,
/s/Kevin B. Salvaggio
Kevin B. Salvaggio, Esquire
Rhode Island Bar No. 6385
127 Dorrance Street, Suite LL
Providence, RI 02903
(401)861-­‐1212
(401)383-­‐9447 (fax)