February 6, 2014 4th Circuit published opinion

United States v Keita

Keita was convicted of identity theft credit card fraud and other charges. He challenged the denial of his speedy trial motion, the admission of business records and the restitution order. The panel affirmed. It held that Keita’ speedy trial motion was properly denied as less than 30 days ran from arrest to indictment once the continuances were excluded. It upheld the admission of the business records as the card issuer kept the potential fraudulent transaction records for business purposes and not in anticipation of trial and the records were relevant to the credit card fraud charges. The panel affirmed as to the restitution order as the trial court only included those losses for which video evidence of the crime existed and the final amount was reasonable under the circumstances.

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