<< ° ° Shawn Holley Partner Direct Dia (310) 566-9622 KNSCIA WITZMAN STR I> OL: Direct Fax: (310) $66-9673 E Malt sholley@kwithiow.com FILED ror Court of California ly of Los Angeles JUL 26 2022, July 26, 2022 9 her neorClerk LC "Reber Sak VIA FACSIMILE ONLY. Hon. Charlaine F. Olmedo SHORTRIDGE FOLTZ CRIMINAL JUSTICE CENTER - Dept. 105 210 W. Temple Street Los Angeles, CA 90012 Re: People v. Daniel Peter Masterson Case No.: BA487932 Judge Olmedo, I am writing to update the Court and all counsel on the status of the MLB v. MLBPA/Bauer arbitration. Since our July 5, 2022 chambers conference, new evidence has come forward in the Bauer matter which will require extensive additional examination of one of the key witnesses. As a result, the time estimate for completion of the matter has been extended to November. As lead counsel, I am working full-time preparing and traveling back and forth to Washington DC for the hearings. Given this substantial time commitment, it will be impossible for me to prepare for the Mas‘erson trial until Bauer is complete, For these reasons, it would be my request that the Masterson trial be continued to late January 2023. I spoke with Mr. Mueller this afternoon to discuss the prospect of a continuance to late January. Mr. Mueller had no objection to the matter being continued, particularly in light of the fact that he anticipates providing the defense with additional discovery in the coming days. ms wise Sodovad os Sarta Monica, Ctra bt | Telephone 305800] Fa SaSH6 0 25 26 27 UEf Qo ° Hon. Charlaine F. Olmedo July 26, 2022 Page 2 Finally, as the Court may recall, I will be in Washington DC the week of August 15 and ‘unable to appear on our next court date. I wanted to be sure to provide you this information well in advance of that date (August 17) so that these issues can be addressed at that time. Respectfully, ai Shawn Holley cc: Reinhold Mueller, Esq. (rmucllerids, lacounty.gov Philip Kent Cohen, Esq. (pcohen ¢ peohenlaw.com) SormpoeH1061 25 6 27 28 sorv000ms616 1 DEFENDANT'S MOTION TO CONTINUE TRIAL