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UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA

CASE NO. 22-80144-CR-SMITH/MAYNARD(s)

UNITED STATES OF AMERICA,

Plaintiff,

vs.

JOFF STENN WROY PHILOSSAINT,

Defendant.

___________________________________/

UNOPPOSED MOTION TO CONTINUE TRIAL

COMES NOW, the defendant, JOFF STENN WROY PHILOSSAINT, by and through 

his undersigned counsel, who would hereby move for a continuance of the currently scheduled 

trial in this case, and in support thereof would show as follows:

1. Defendant was charged by superseding indictment with multiple financial crimes. 

Today, defendant entered guilty pleas to counts 1, 2 and 3 of the superseding 

indictment.

2. Defendant remains charged with count 4, Obtaining Citizenship by Fraud, in violation 

of Title 18 U.S.C. § 1425(a), and is proceeding to trial on that count.

3. The defense requires additional time to prepare to defend this charge. To date,

virtually all defense preparation has centered around counts 1, 2 and 3. The discovery 

in this case is voluminous, and the undersigned counsel has received two separate 1 

TB hard drives containing discovery.

4. Undersigned counsel is beginning a trial before the Honorable Donald Middlebrooks 

in the case of U.S.A. v. John Moore, Jr. and Tanner Mansell in Case No. 22-80073-

CR-MIDDLEBROOKS. Jury selection is to begin this Wednesday, November 16, 

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2022. It is anticipated that this trial will last until November 21 or 22, 2022.

5. In addition to finalizing plea negotiations in the instant case, almost all the 

undersigned counsel’s time has been spent preparing for this week’s trial before 

Judge Middlebrooks. As such, counsel has not been able to begin preparing for trial 

on count 4 of Mr. Philossaint’s case.

6. Until just a few days ago, counsel believed that Mr. Philossaint would plead guilty to 

all counts of the indictment this morning. As such, preparation for the trial was 

delayed.

7. All other defendants have moved for a continuance of the currently scheduled trial.

8. This case has not been continued previously.

9. The undersigned counsel has discussed this matter with AUSA Marc Osborne, who 

has no objection to the requested continuance.

10. Defendant agrees that the time of continuance is excludable under the Speedy Trial 

Act. Further, the rights of the defendants and the public to a speedy trial are 

outweighed by the need for additional time by all defendants to prepare for trial.

WHEREFORE, based upon the foregoing, defendant respectfully requests that the trial in 

this matter be continued.

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that the foregoing has been electronically filed and served on 

counsel for all parties via CM/ECF this 14

th day of November, 2022.

Respectfully submitted,

LAW OFFICES OF IAN GOLDSTEIN P.A.

Counsel for Defendant Philossaint

330 Clematis Street, Suite 209

Case 9:22-cr-80144-RS Document 92 Entered on FLSD Docket 11/14/2022 Page 2 of 3
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West Palm Beach, FL 33401

Tel: (561) 600-0950

Email: ian@iangoldsteinlaw.com

/s/ Ian J. Goldstein

IAN J. GOLDSTEIN, ESQUIRE

Florida Bar No. 0085219

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