Bikundi v. United States

Issue: (1) Whether a district court granting an ends-of-justice continuance under the Speedy Trial Act of 1974 violates the requirement that the court set forth its reasons for "such continuance" when it sets forth adequate reasons only for earlier continuances; (2) whether, at the sentencing of a fraud defendant whose conduct the district court found included both "pervasive" fraud and legitimate activities, the government retains the burden of proving the specific scope of the fraudulent conduct that results in loss under the Sentencing Guidelines, restitution and forfeiture.