UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
UNITED STATES OF AMERICA :
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v. :
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xxxxxxxxxxx, : Criminal No. xxxxxxxx(JGP)
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Defendant. :
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MOTION FOR LEAVE TO LATE-FILE PRETRIAL MOTION
xxxx, through counsel, respectfully moves the court for leave to late-file the attached Motion to Suppress Tangible Evidence.
As grounds for this Motion, Mr. xxxxxxx, through counsel, states:
1. Mr. xxxxxxx was arrested on November 29, 1997, and was arraigned before the Honorable John Garrett Penn. The court ordered deadlines by which defense motions were to be filed.
2. After further investigation and review of discovery materials, undersigned counsel believes the attached motion to suppress must be filed.
Therefore, counsel respectfully requests to be permitted to late-file the attached defense motions on behalf of Michael A. xxxxxxx.
Respectfully submitted,
A.J. KRAMER
FEDERAL PUBLIC DEFENDER
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Valencia Rainey
Assistant Federal Defender
625 Indiana Avenue, N.W. #550
Washington, D.C. 20004
(202)208-7500
CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing Motion for Leave to Late-File Motions has been personally served upon the Office of the United States Attorney, 555 Fourth Street, N.W., Washington, D.C. 20001 this 10th day of February 1998, for Assistant United States Attorney Leutrell M.C. Osborne, II, Esq., by leaving a copy in the box designated for the United States Attorney's Office in the clerk's office of the United States District Court for the District of Columbia.
Valencia Rainey
Assistant Federal Public Defender
FOR THE DISTRICT OF COLUMBIA
UNITED STATES OF AMERICA :
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v. : Criminal No. xx-496(JGP)
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xxxxxxxx A. xxxxxxx, :
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Defendant. :
___________________________________:
O R D E R
This matter having come before the Court on a Motion For Leave to Late-File Pretrial Motions, and good cause having been shown, it is this day of February 1998,
HEREBY ORDERED that the Motion is granted.
JOHN GARRETT PENN
UNITED STATES DISTRICT JUDGE
Copies To:
Valencia Rainey, Esq.
Assistant Federal Public Defender
625 Indiana Avenue N.W.
Washington, D.C. 20004
(202)208-7500
Leutrell M.C. Osborne, II,Esq.
Assistant United States Attorney
Office of the United States Attorney
555 Fourth St., N.W.
Washington, D.C. 20001
(202)514-7736