IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

UNITED STATES OF AMERICA :

: Cr. No.

v. :

:

:

xxxxxxxxxxxxxxxx :

:

MOTION FOR WRIT OF MANDAMUS

TO COMPEL THE U.S. PAROLE COMMISSION'S COMPLIANCE WITH

TITLE 18 OF THE UNITED STATES CODE § 4214(C)

Defendant xxxxxxxxxx, through counsel, respectfully moves the court to issue a writ of mandamus to compel the U.S. Parole Commission to comply with Title 18 of the for leave to file the attached Motion to Suppress Tangible Evidence three days late, and as grounds, shows the court:

l. Ms. xxxxxxx was arraigned on an indictment charging possession with intent to distribute cocaine base and possession with intent to distribute cocaine base near a school. Arraignment was held on December 3, l992. Counsel for defendant was given until December l8, l992 to file any pre-trial motions.

2. At arraignment, Ms. xxxxxxx was represented by Leigh Kenney, an Assistant Federal Defender. Due to Ms. Kenney's caseload, undersigned counsel arranged for the transfer of the case to her. Undersigned counsel entered an appearance on December l4, l992.

3. Once counsel entered her appearance, she contacted Corbin Weiss, Esq., the Assistant United States Attorney assigned to this case, regarding discovery. Mr. Weiss made discovery available to counsel as soon as he was out of trial, with the last documents being furnished on Monday, December 2l.

4. Given cousel's substitution for Ms. Kenney and her request for discovery at a time when Mr. Weiss was engaged in trial, this Motion is delayed by three days. Mr. Weiss does not oppose this request for late-filing.

For the foregoing reasons, counsel requests that her Motion to Late-File be granted.

Respectfully submitted,

A.J. KRAMER

FEDERAL PUBLIC DEFENDER

________________________

Reita Pendry

Assistant Federal Defender

625 Indiana Avenue, N.W. #550

Washington, D. C. 20004

(202)208-7500