DISTRICT COURT OF THE VIRGIN ISLANDS 
DIVISION OF ST. THOMAS AND ST. JOHN 
UNITED STATES OF AMERICA, 
Plaintiff, 
v. 
KING BOB LEONARD and TOMMY RAMIREZ, 
Defendants. 
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Criminal No. 2019-12 
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ATTORNEYS: 
 
Gretchen Shappert, United States Attorney 
Delia L. Smith, AUSA 
Jennifer H Blecher, AUSA 
United States Attorney’s Office 
St. Thomas, U.S.V.I. 
 
For the United States of America, 
 
Allan A. Rivera-Fernandez 
Luis Rafael Rivera Law Office 
San Juan, PR 
Darren John-Baptiste 
Law Offices of Darren John-Baptiste 
St. Thomas, VI 
 
For King Bob Leonard. 
 
Alex Omar Rosa-Ambert 
Rosa-Ambert Law Offices  
San Juan, PR 
 
For Tommy Ramirez. 
 
ORDER 
GÓMEZ, J. 
 
Before the Court are the motions of King Bob Leonard and 
Tommy Ramirez to continue the trial in this matter.   
 
On March 7, 2019, the Grand Jury returned an indictment 
charging King Bob Leonard (“Leonard”) and Tommy Ramirez 
Case: 3:19-cr-00012-RAM-RM   Document #: 87   Filed: 10/24/19   Page 1 of 4
United States v. Leonard et al. 
Criminal No. 2019-12 
Order 
Page 2 
 
(“Ramirez”) jointly with one count of conspiracy to possess with 
the intent to distribute cocaine in violation of 
21 U.S.C. § 841 and 846, one count of attempted possession with 
intent to distribute cocaine in violation of 
21 U.S.C. § 841 and 846 and 18 U.S.C. § 2, and one count of use 
of a communication facility to facilitate a felony in violation 
of 21 U.S.C. § 843. 
 
On March 13, 2019, Leonard and Ramirez were arraigned on 
the indictment. At their arraignment, a trial date was set for 
April 29, 2019. Subsequently, the trial date was continued on 
multiple occasions after Leonard and Ramirez each moved to 
continue. A trial date was set for October 28, 2019. 
 
On October 16, 2019, Leonard filed a motion to continue the 
trial date. In his motion, Leonard requests a continuance of the 
trial date until a date after December 9, 2019. Leonard requests 
such a continuance for several reasons. First, Leonard requires 
additional time to pursue possible plea negotiations. Second, 
Leonard requires additional time to fully prepare for trial. 
Third, Leonard has retained an expert witness who requires 
additional time to prepare a report. 
 
On October 21, 2019, Ramirez also filed a motion to 
continue the trial date. In his motion, Ramirez requests a 
continuance of the trial date until a date after December 2, 
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United States v. Leonard et al. 
Criminal No. 2019-12 
Order 
Page 3 
 
2019. Ramirez requests such a continuance because he requires 
additional time to pursue possible plea negotiations. 
 
While the Speedy Trial Act requires that defendants be 
tried within seventy days of indictment, the Court specifically 
finds that extending this period would be in the best interest 
of justice for several reasons. First, an extension is necessary 
to allow Leonard and Ramirez time to pursue possible plea 
negotiations. Second, Leonard and Ramirez made their requests 
with the advice and consent of counsel. Third, without an 
extension, Leonard would be unable to present his retained 
expert at as a witness at trial. 
 
Consistent with these concerns, the United States Court of 
Appeals for the Third Circuit has recognized that “whether or 
not a case is ‘unusual’ or ‘complex,’ an ‘ends of justice’ 
continuance may in appropriate circumstances be granted.”  
United States v. Fields, 39 F.3d 439, 444 (3d Cir. 1994); United 
States v. Dota, 33 F.3d 1179(9th Cir. 1994) (“An ends of justice 
continuance may be justified on grounds that one side needs more 
time to prepare for trial [even if the] case [i]s not 
‘complex.’”); see also United States v. Lattany, 982 F.2d 866, 
883 (3d Cir. 1992) (“[T]he district court did not abuse its 
discretion when it delayed the trial to give counsel . . . 
opportunity to . . . decid[e] upon and prepar[e] an appropriate 
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United States v. Leonard et al. 
Criminal No. 2019-12 
Order 
Page 4 
 
defense.”); United States v. Brooks, 697 F.2d 517, 522 (3d Cir. 
1982) (holding there was no abuse of discretion where district 
court found that  multiple count, multiple defendant “case was 
complex and required additional time for adequate 
preparation.”); cf. United States v. Santiago-Becerril, 130 F.3d 
11, 17 (1st Cir. 1997) (explaining that, where a defendant had 
moved to continue his trial due to his counsel’s unavailability, 
the “period of delay” caused by an ends of justice continuance 
includes the time “reasonably required to schedule a new trial 
date” in “consideration of the court’s calendar”). 
 
The premises considered; it is hereby   
 
 
ORDERED that Leonard’s motion to continue, ECF No. 80, and 
Ramirez’s motion to continue, ECF No. 83, are GRANTED; it is 
further 
 
ORDERED that the jury trial previously scheduled to 
commence on October 28, 2019, is hereby RESCHEDULED to commence 
on January 6, 2020; and it is further 
 
ORDERED that the time beginning from the date of this order 
granting an extension through January 6, 2020, shall be excluded 
in computing the time within which the trial for Leonard and 
Ramirez must be initiated pursuant to 18 U.S.C. § 3161.  
 
 
 
 
 
  
 
 
S\ 
 
 
 
 
 
 
  
 
 
Curtis V. Gómez 
 
 
 
 
 
 
 
 
District Judge 
Case: 3:19-cr-00012-RAM-RM   Document #: 87   Filed: 10/24/19   Page 4 of 4