Caolan Gormley, 24, has denied a charge of conspiracy to assist illegal immigration.
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The trial of a haulier accused over a people-smuggling operation which ended in the deaths of 39 men, women and children has been delayed until 2023.
The victims, all Vietnamese nationals, were found dead shortly after the container they were in arrived in Essex on a ferry from Zeebrugge in Belgium in the early hours of October 23 2019.
Caolan Gormley, 24, has denied a charge of conspiracy to assist illegal immigration.
It is alleged he allowed vehicles in his road haulage fleet to be used to transport of migrants into the UK.
39 bodies were found inside a lorry container on the Waterglade Industrial Park in Grays, Esse
Stefan Rousseau
Gormley, who is on unconditional bail, had been due to go on trial next June at the Old Bailey.
But at a hearing on Wednesday, Judge Mark Lucraft QC put the case back to January 31 2023.
Setting out the difficulties of finding trial slots in the pandemic, he told how defendants in custody took priority.
Gormley, of Kedew Road in Caledon, County Tyrone, Northern Ireland, did not attend the hearing but was represented by his lawyer.
Judge Lucraft said he would review the situation at a hearing on March 2 next year.