Case 6:14-cr-00005-MHS-JDL Document 16 Filed 03/25/14 Page 1 of 3 PageID #: 53

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION UNITED STATES OF AMERICA VS. JOE WHITE

CASE NO. 6:14cr5 (Judge Michael H. Schneider)

W HITES U NOPPOSED M OTION F OR C ONTINUANCE

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.1 And count two charges him with aggravated identity theft.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. scheduling. Whites case is set on April 7, 2014, for a pretrial conference and trial

/ 18 U.S.C. 1001(a)(2) & (a)(3). / 18 U.S.C. 1028A(a)(1). Page -1-

Case 6:14-cr-00005-MHS-JDL Document 16 Filed 03/25/14 Page 2 of 3 PageID #: 54

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. trial. 8. White therefore asks that his case be continued for 60-90 days, so that The Government has likewise been busy preparing for the Mahmood

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) colin@khalawyers.com
Page -2-

Case 6:14-cr-00005-MHS-JDL Document 16 Filed 03/25/14 Page 3 of 3 PageID #: 55

C ERTIFICATE O F C ONFERENCE
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

C ERTIFICATE OF S ERVICE
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: Nathaniel.Kummerfeld@usdoj.gov Nathaniel Kummerfeld Assistant U.S. Attorney Eastern District of Texas Tyler Division

/s/ Colin B. Amann

Page -3-