UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA



UNITED STATES OF AMERICA :

:

v. :

:

xxxxxxxxxxx, : Criminal No. xxxxxxxx(JGP)

:

Defendant. :

:



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











________________________

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 :

:

v. : Criminal No. xx-496(JGP)

:

xxxxxxxx A. xxxxxxx, :

:

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