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) colin@khalawyers.com

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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: Nathaniel.Kummerfeld@usdoj.govNathaniel KummerfeldAssistant U.S. AttorneyEastern District of TexasTyler Division

/s/ Colin B. Amann

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