UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

UNITED STATES OF AMERICA :

v. : CRIMINAL NO. xx-139--01 (RCL)

xxxxxxxxxxxxxxxxxxxx :

UNOPPOSED MOTION FOR EXTENSION OF TIME WITHIN WHICH TO

FILE PRE-TRIAL MOTIONS AND

INCORPORATED MEMORANDUM OF SUPPORTING POINTS

xxxxxxxxxx, through undersigned counsel, respectfully moves this Honorable Court for a seven day extension of time within which to file his pre-trial motions in this case.

As grounds for this motion, undersigned counsel states:

1. At the September 22, 1998 status hearing in this case, October 1, 1998 was set as the deadline for the filing of any additional pre-trial motions by the defense.

2. Since the September 22^nd status date, Undersigned has been in trial in United States v. Whitaker, before Judge Sporkin. As a result of undersigned's trial schedule, it has been impossible for undersigned to dedicate the necessary time to review the voluminous file in this case and determine whether any additional motions should be filed.

3. In addition, although there is additional discovery which the government will be providing in the near future, undersigned has not received this new information as of yet.

4. AUSA Harry Benner has stated that the government has no objection to the granting of this motion.

WHEREFORE, for the foregoing reasons, and for any other reasons this Court may deem just and proper, Mr. xxxxxxxx, through counsel, respectfully requests that this Motion be granted and that this Court extend the time for the filing of pre-trial motions.

Respectfully submitted,

L. Barrett Boss

Assistant Federal Public Defender

625 Indiana Avenue, N.W.

Washington, D.C. 20004

(202) 208-7500

CERTIFICATE OF SERVICE

I hereby certify that a true and accurate copy of the foregoing motion was served upon Harry Benner, Assistant United States Attorney by hand delivering a copy to a receptacle at the United States District Courthouse, 3rd and Constitution Avenue, N.W., Washington, D.C. provided for pleadings upon the Office of the United States Attorney, on this 1^st day of October, 1998.

L. Barrett Boss

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

UNITED STATES OF AMERICA :

v. : CRIMINAL NO. xx-139--01 (RCL)

xxxxxxxxxxxxx :

ORDER

This matter having come before the Court on an Motion For Extension Of Time Within Which To File Pretrial Motions and the Incorporated Memorandum of Supporting Points, and good cause having been shown, it is this day of October, 1998, HEREBY

1) ORDERED that the defendant Andrew's motion is granted; and it is further ordered

2) ORDERED that the time for filing pretrial motions is extended to October 8, 1998.

ROYCE C. LAMBERTH

United States District Judge

Copies To:

L. Barrett Boss

Office of the Federal Public Defender

625 Indiana Avenue, N.W.

Washington, D.C. 20004

Harry Benner

Office of the United States Attorney

555 Fourth Street, N.W.

Washington, D.C. 20001