IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
UNITED STATES OF AMERICA :
:
v. :
: CRIMINAL NO. xx-xxxx(JGP)
xxxxxxxxxxx, :
:
Defendant. :
______________________________:
MOTION FOR LEAVE TO LATE-FILE PRETRIAL MOTIONS
xxxxxxxxxxx, through counsel, respectfully moves the court for leave to late-file the attached Motion to Suppress Statements, Motion to Suppress Physical Evidence, Motion to Bifurcate, Motion to Dismiss Multiplicitous Counts, and Motion for Modification of Release.
As grounds for this Motion, Anthony T. Leake, through counsel, states:
1. Mr. xxxxxx was arrested on October 28, 1997, and was arraigned on December 9, 1997. The court ordered defense motions to be filed by December 30, 1997.
2. Undersigned counsel was unable to file the attached motions by the due date of December 30, 1997. Undersigned counsel was on leave from December 22, 1997 until January 5, 1998.
3. In addition, undersigned counsel was unable to complete the motions by the due date due to the fact that two assistant federal defenders had left our office, leaving undersigned counsel with an increased caseload, and the reassignment of cases requiring immediate action.
4. Undersigned counsel does not object to government's request for additional time to respond to defense motions.
Therefore, counsel respectfully requests to be permitted to late-file the attached defense motions on behalf of Mark Anthony xxxxxx.
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 18th day of December 1997, for Assistant United States Attorney Sima Sarrafan, 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
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
UNITED STATES OF AMERICA :
:
v. :
: CRIMINAL NO. 97-467(JGP)
MARK xxxxxx, :
:
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 January 1998,
HEREBY ORDERED that the Motion is granted.
John Garrett Penn
United States District Judge
Copies To:
Sima Sarrafan, Esq.
Assistant United States Attorney
Office of the United States Attorney
555 Fourth St., N.W.
Washington, D.C. 20001
Valencia Rainey, Esq.
Assistant Federal Public Defender
625 Indiana Avenue N.W.
Washington, D.C. 20004