govinfo:USCOURTS-ctd-3_26-cr-00064-0

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UNITED STATES DISTRICT COURT 
DISTRICT OF CONNECTICUT 
UNITED STATES OF AMERICA, : 
 Plaintiff, : 
 : 
 v. : Criminal No. 3:26-cr-64-1-OAW 
 : 
MICHAEL JOSEPH MEADE, et al., : 
 Defendants. : 
ORDER REGARDING STATUS REPORT 
THIS ACTION is before the court upon Defendant Michael Joseph Meade’s Status 
Report. ECF No. 69 . The court presumes Mr. Meade’s and Attorney Daniel Erwin’s 
familiarity with the relevant procedural history,1 and recounts it only as necessary in 
articulating why it declines to schedule “a brief conference call” which “counsel would not 
oppose,” but does not request, despite the deadline of June 18, 2026, for any motion to 
continue jury selection as presently scheduled for July 16, 2026. See ECF Nos. 68, 69. 
 
I. RELEVANT PROCEDURAL HISTORY 
Mr. Meade is charged with tax evasion and various other tax crimes, in violation of 
26 U.S.C. §§ 7201, 7203, 7212(a), and 7206(2), and 18 U.S.C. §§ 2 and 371. ECF No. 
1. Upon learning that he “wants to represent himself,” the court referred Mr. Meade to a 
United States Magistrate Judge for a hearing pursuant to Faretta v. California, 422 U.S. 
806 (1975). ECF Nos. 27, 30 . Faretta requires the court to: (i) ensure that Mr. Meade 
 
1 At Mr. Meade’s initial appearance, on April 22, 2026, The Honorable Maria E. Garcia appointed Attorney 
Erwin as Mr. Meade’s standby counsel until such time as the court could determine whether Mr. Meade 
“will be permitted to represent himself.” ECF No. 12. Attorney Erwin continues to serve in that capacity, 
and has made several filings on Mr. Meade’s behalf. See, e.g., ECF Nos. 53, 54, 59, 69. 

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“knowingly and intelligently forgo[es]” the right to counsel by making him “ aware of the 
dangers and disadvantages of self -representation,” and (ii) establish a record that he 
“knows what he is doing and his choice is made with eyes open.” 422 U.S. at 835–36 
(internal citations and quotation marks omitted). Only then may Mr. Meade proceed pro 
se in this case. Id. 
The Honorable United States Magistrate Judge S. Dave Vatti promptly convened 
a Faretta hearing on May 8, 202 6, see ECF No. 42 , at which Mr. Meade “declined to 
engage in any colloquy with the [c]ourt,” see ECF No. 44, for thirty minutes, see ECF No. 
47. Judge Vatti determined that His Honor could not “make a finding of [Mr. Meade’s] 
knowing and intelligent waiver of [his] right to counsel” and continued the hearing to May 
22. See ECF No. 44 (citing Faretta, 422 U.S. 806). 
At the May 22 hearing, Judge Vatti explained to Mr. Meade that his cooperation 
was required to make the necessary findings under Faretta. ECF No. 56; see also 422 
U.S. at 835–36. However, Mr. Meade “refused to answer” any of Judge Vatti’s questions; 
again, he “remained silent,” “made no eye contact,” and “made no facial expressions ,” 
see ECF No. 5 6, for seventeen minutes , see ECF No. 55. Judge Vatti continued the 
hearing to June 1 to “give” Mr. Meade more “time to reconsider” his lack of engagement. 
ECF No. 56. When Mr. Meade repeated such behavior for forty-three minutes on June 
1, Judge Vatti continued the hearing to June 9.2 See ECF Nos. 60, 62. 
Judge Vatti “described in detail the benefits of having counsel,” the “disadvantages 
of self-representation,” and “the specific questions that comprise the Faretta inquiry” at 
the June 9 hearing. ECF No. 64. His Honor “provided Mr. Meade and [Attorney Erwin] 
 
2 Notwithstanding, Judge Vatti found that that Mr. Meade “is intelligent, articulate and understands 
English,” and “heard the Court's explanation of the purpose of a Faretta hearing.” ECF No. 62. 

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in writing an explanation of the purpose of the Faretta hearing, the benefits of having 
counsel and downsides of self-representations and the questions the [c]ourt intended to 
ask him.” Id. The court also explained that it “did not intend to stand in the way of Mr. 
Meade’s self-representation if that is what he wished to do so long as it had the Faretta 
discussion with him and could make a finding of knowing and intelligent waiver.” Id. Still, 
Mr. Meade “refused to answer” the court’s questions, “refused to make any eye contact,” 
and “made no facial expressions whatsoever .” Id. After forty minutes, Judge Vatti 
continued the hearing a final time, to June 17. See ECF Nos. 63, 64. 
Despite his silence before Judge Vatti, Mr. Meade has represented—at his initial 
appearance before The Honorable United States Magistrate Judge Maria E. Garcia, and 
across several filings submitted by counsel —that his “silence is his intended form of 
protest,” see ECF No. 53, at 2 , specifically against the “jurisdiction and authority” of th e 
court, see ECF No. 12, and that he will continue, as he apparently sees it, “exercising his 
constitutional right to silence ,” see ECF No. 59, at 1 . Indeed, he would rather remain 
detained than acknowledge the court’s authority to set “minimal conditions necessary to 
assure his appearance and the safety of the community” if released pending trial. ECF 
No. 17. 
Meanwhile, the time within which Mr. Meade’s trial must commence ( pursuant to 
the Speedy Trial Act) has continued to run. See 18 U.S.C. § 3161. 
As the parties are aware, see ECF Nos. 43, 51, 58, 66, 68 , the Speedy Trial Act 
requires a criminal trial to commence within seventy days of an indictment or arraignment, 
whichever occurs later. See 18 U.S.C. § 3161(c)(1) . It “is intended both to protect the 
defendant from undue delay in his or her trial and to benefit society by ensuring a quick 

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resolution.” United States v. Kelly, 45 F.3d 45, 47 (2d Cir. 1995). Nevertheless, any party 
may propose a trial date beyond the seventy -day period and move the court to exclude 
the resulting delay from its speedy trial computation. Id. (citing 18 U.S.C. § 3161(h)). The 
court repeatedly has brought this to the attention of Mr. Meade and his 
codefendant, Chet Lee West. See ECF Nos. 43, 51, 58, 66, 68. 
Until the government, Mr. Meade, or Mr. West successfully move s the court for 
such a continuance “ on the basis . . . that the ends of justice served by [a continuance] 
outweigh the best interest of the public and the defendant in a speedy trial,” see 18 U.S.C. 
§ 3161(h)(7)(A), the Speedy Trial Act requires that this case proceed to trial on or before 
July 16, 2026 ,3 see ECF No. 42 . Consequently, the court has ordered the parties to 
attend a discovery conference before Judge Vatti following the conclusion of Mr. Meade’s 
Faretta hearing, see ECF Nos. 51, 68, and, separately, that any motions to continue the 
current trial date be submitted on or before June 18, 2026, see ECF Nos. 66, 68, so that 
the court may carefully consider the merits of any such motion, and so the Jury Clerk may 
have adequate time to summon a sufficient pool of qualified and available potential jurors. 
 
 
 
3 The Speedy Trial Act excludes “[a]ny period of delay resulting from other proceedings concerning the 
defendant, including but not limited to . . . delay resulting from any pretrial motion, from the filing of the 
motion through the conclusion of the hearing on, or other prompt disposition of, such motion,” or “delay 
reasonably attributable to any period, not to exceed thirty days, during which any pro ceeding concerning 
the defendant is actually under advisement by the court.” 18 U.S.C. §§ 3161(h)(1)(A), (h)(1)(H); see also 
United States v. Akhavan, 523 F. Supp. 3d 443, 447 (S.D.N.Y. 2021), aff'd sub nom. United States v. 
Patterson, No. 21-1678-CR, 2022 WL 17825627 (2d Cir. Dec. 21, 2022). Accordingly, the time spent 
completing Mr. Meade’s Faretta hearing would be excluded from any speedy trial calculation, such that a 
requested continuance beyond July 16 would not necessarily exceed the seventy-day limit. Id. Should 
any party seek to continue the trial under such provision of the Speedy Trial Act, see 18 U.S.C. §§ 
3161(h)(1), such party may file a motion to do so containing reasoning and authority, but see 18 U.S.C. § 
3161(h)(7)(A). Notwithstanding, based on Mr. Meade’s representations, the absence of any motion to 
continue the trial, and the impending deadline for any party to move the court to continue trial, see ECF 
No. 68, the court declines any sua sponte continuance of trial or of the pretrial deadlines. 

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II. MR. MEADE’S STATUS REPORT 
Ahead of the upcoming fifth and final Faretta hearing, see ECF No. 64, Attorney 
Erwin filed a status report “to aid the court in anticipating [the] scheduling needs” of this 
case, see ECF No. 69, at 1 . Although it does not affirmatively present any particular 
requests, it implies that the court , sua sponte, should address “some of the paradoxical 
and uncertain vagaries of this case.” Id. 
For the reasons that follow, the court declines to do so. 
 
A. Hypothetical Appeal 
Attorney Erwin represents that he would appeal any order by Judge Vatti requiring 
Mr. Meade to proceed with counsel , but that such counsel would be unable “to prepare 
for an immediate trial while . . . pursuing an appeal on the very issue of representation .” 
ECF No. 69, at 2. The court has set jury selection for July 16 in accordance with the 
Speedy Trial Act, along with corresponding trial deadlines which would allow the court to 
carefully consider any pretrial motions. ECF No. 68. However, for more than one month, 
Mr. Meade has been free to move to continue his trial , see ECF No. 43, and he remains 
free to do so now, see ECF No. 68, whether to prepare for trial, to further litigate the 
appointment of counsel, or for any other permissible reason . Mr. Meade even 
acknowledges this in the status report. See ECF No. 69, at 3 (indicating that the 
parties “have the power to make such motion”). 
Accordingly, the court declines to alter its deadlines sua sponte. 
 
 

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B. Faretta Hearing Delays 
Mr. Meade argues that “the Faretta hearing should have concluded several weeks 
ago,” and that the “delay” is “cutting into [his]—and possibly Mr. West’s—speedy trial and 
preparation time.” ECF No. 69, at 2. 
“[D]istrict courts routinely direct defendants considering self -representation to 
spend some time thinking about the risks inherent in that course.” Jackson v. Perez, No. 
15-CV-1403(EK)(LB), 2020 WL 7123162, at *10 (E.D.N.Y. Dec. 4, 2020 ). However, the 
several Faretta hearings in this case have been atypical in terms of their time commitment 
due to Mr. Meade’s repeated lack of engagement. Id. Typically, a defendant is willing to 
engage in an “extensive colloquy on the record,” so the presiding judge can determine 
whether that defendant “understands the nature of the charges against him . . . and the 
maximum potential penalties if he is convicted of those charges, understands the benefits 
of having counsel represent him and the risks/disadvantages of representing himself, and 
that he has the requisite mental capacity to comprehend the consequences of 
relinquishing the right to have appointed counsel.” ECF No. 48 (noting that Mr. West did 
so at his sole Faretta hearing, on May 8). Mr. Meade has chosen a different approach. 
See ECF Nos. 44, 56, 62, 64. 
As such, the pretrial deadlines remain appropriate in light of the ongoing Faretta 
determination and the requirements of the Speedy Trial Act. 18 U.S.C. § 3161(c)(1). The 
status report contains no authority holding that “a judge must stop all proceedings and 
decide immediately whether to grant a request to proceed pro se, and this [c]ourt is aware 
of none.” Jackson, 2020 WL 7123162, at *10 (acknowledging also that “Second Circuit 
case law . . . supports the notion that self -representation need not begin 

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instantaneously”). “Faretta does not require it,” either. Id. As Judge Vatti repeatedly has 
explained to Mr. Meade, see ECF Nos. 44, 56, 62, 64, Faretta “requires the defendant's 
decision [to proceed pro se] to be knowing, voluntary, and unequivocal,” see Jackson, 
2020 WL 7123162, at *10. 
Furthermore, Judge Vatti does not seem to have been persuaded that Mr. Meade’s 
silence at the Faretta hearings is a valid form of protest against the court’s jurisdiction and 
authority. See generally, ECF Nos. 12; 17; 53, at 2; 59, at 1. And again, the status report 
contains no authority to support any such contention. 
 
C. Status Conference 
Attorney Erwin represents that he (and, presumably, Mr. Meade) “would not 
oppose a brief conference call” with the court , though without affirmatively requesting or 
moving for one , insofar as the purpose is “to aid the court in anticipating s cheduling 
needs.” ECF No. 69, at 1. 
The parties and counsel are free to meet and confer, at their convenience. See 
Fed. R. Crim. P. 16.1. And until the parties have attended the discovery conference before 
Judge Vatti, which was ordered by the undersigne d, see ECF Nos. 51 (citing Fed. R. 
Crim. P. 17.1), 68 (requiring the parties to confer “in good faith”) , the court does not find 
that any additional conferences would be productive while the parties determine whether 
they will have enough time to adequately prepare for trial as currently scheduled. ECF 
No. 51 . This finding is firmly supported by the record before the undersigned , as 
described in this order and as is evidenced throughout the docket. 
 

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III. CONCLUSION 
Whereas Mr. Meade and Attorney Erwin might be concerned about their ability to 
adequately and competently prepare for trial, see ECF No. 69, at 2 (noting “[i]t would not 
be workable, procedurally or practically, to prepare for an immediate trial . . . .”), the court 
reminds them of the June 18 deadline to move for a continuance of trial, see ECF No. 
68, which presently is as much in the control of defense counsel as the decision to ignore 
Judge Vatti across four separate Faretta hearings has remained in the control of Mr. 
Meade, see ECF Nos. 44, 56, 62, 64. And the current pretrial deadlines are the result of 
the ongoing defense decision (fully in their control) not to propose an alternative trial 
schedule consistent with the Speedy Trial Act. See ECF Nos. 43, 51, 58, 66, 68. 
The court intends for Mr. Meade to carefully consider each of these concerns and 
the impact of his ongoing behavior. After all, defense counsel cites no law which supports 
his suggestion that a defendant can invoke his Fifth Amendment right to remain silent at 
a Faretta hearing; or, for that matter, during court inquiries as to how the defendant pleads, 
whether he elects to have a trial before a judge or a jury, whether he understands his right 
to testify (or to decline to testify), whether he wishes to select a particular juror, or whether, 
at a Frye hearing, he understands any government offer at a resolution of this case short 
of trial, and whether he understands his exposure to incarceration if he rejects any such 
offer. Furthermore, defense counsel fails to explain why Defendant’s refusal to comply 
with any court instruction to respond to such questions should not be deemed “contempt,” 
see ECF No. 53, at 7, of even the avoidable civil variety , see, e.g., International Union, 
United Mine Workers of America v. Bagwell, 512 U.S. 821, 831 (1994). Indeed, the court 
must be permitted to carry out its duty to advance this case. 

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Accordingly, Attorney Erwin SHALL present Mr. Meade with a printed copy of this 
order and also read it aloud to him in its entirety during the Faretta hearing on June 17, 
on the record in open court. Before doing so, Attorney Erwin SHALL inform Judge Vatti 
of this order and defer to His Honor’s determination as to when during the hearing this 
order should be read to Mr. Meade. 
To be clear, this order neither requires nor discourages Mr. Meade’s filing of any 
motion or appeal hypothetically referenced in his status report. See ECF No. 69 . 
Similarly, it does not prejudge any such motions or appeals, nor judge whatever beliefs 
might be motivating Mr. Meade’s “protest” in this case. See generally, ECF Nos. 12; 17; 
53, at 2; 59, at 1 . It merely is intended to encourage Mr. Meade to weigh his available 
options, and to assess the consequences of his approach to this case. 
Once more, the court advises Mr. Meade that “the right to self-representation is not 
without limits, ” including limits imposed by “‘the rules of procedure and courtroom 
protocol.’” Clark v. Perez, 510 F.3d 382, 395 (2d Cir. 2008) (quoting McKaskle v. Wiggins 
465 U.S. 168, 173, (1984)); see also Faretta, 422 U.S. at 834 n. 46. 
Finally, the court thanks Judge Vatti for His Honor’s time and attention to this case, 
and Attorney Erwin for his public service. 
 
 IT IS SO ORDERED at Hartford, Connecticut, on this 17th day of June, 2026. 
 /s/ 
 OMAR A. WILLIAMS 
 UNITED STATES DISTRICT JUDGE 

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