Appellate Term, Second Department · March 20, 2026 · 89 Misc 3d 5
People v Bergman
Read the official decision: 89 Misc 3d 5
Holding The court affirmed the conviction, holding that the People satisfied their due diligence obligations under CPL 245.20 by providing sufficient disclosure letters regarding police officer misconduct. Additionally, the court found that the People validly stated ready within the statutory 90-day period, as the speedy trial clock was tolled by executive orders until October 4, 2020.
The court’s words
the People adequately disclosed, prior to their filing of the December 30, 2020 COC, that there were no misconduct allegations
89 Misc 3d 5, at the official text
the People satisfied their obligation of due diligence when they filed their December 30, 2020 COC
89 Misc 3d 5, at the official text
the People validly stated ready on December 30, 2020, which was less than 90 days after the speedy trial clock began to run
89 Misc 3d 5, at the official text
| Court | Appellate Term, Second Department |
|---|---|
| Decided | March 20, 2026 |
| Citation | 89 Misc 3d 5 |
| Area of law | Criminal Procedure |
| Week | Week ending March 21, 2026 |
| Official text | Official decision: 89 Misc 3d 5 |
| Source feed | New York advance sheet: 26nyadv39.pdf |
| Law Watch record id | 796 |
Recommended citation
ESQ HQ, New York Law Watch, People v Bergman, 89 Misc 3d 5 (Appellate Term, Second Department, March 20, 2026), https://esqhq.com/decisions/89-misc-3d-5/
How this record was made
Holding drafted by Law Watch’s in-house model, graded by three reviewers; every quotation verified word for word against the official text.
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