IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
UNITED STATES OF AMERICA :
:
v. :
: CRIMINAL NO. xx-xxxx(EGS)
xxxxxxxx xxxxxxxxx, :
:
Defendant. :
______________________________:
UNOPPOSED MOTION FOR LEAVE TO LATE-FILE SUPPRESSION MOTION
xxxx x. xxxxxxxxxx, through counsel, respectfully moves the court for leave to late-file the attached Motion to Suppress Tangible Evidence and Statements, and as grounds shows the court:
1. Ms. xxxxxxxx was arrested on June 14, 1997. She was charged by indictment with carrying a pistol without a license, and possession of an unregistered firearm and ammunition, in violation of sections 3204(a), 2311(a), and 2361(3), of the District of Columbia Code.
2. Undersigned counsel was unable to file the attached motion by the due date because she was preparing for trial in another case, and because of a heavy case load. Moreover, assumning that Ms. xxxxxxxx does not accept the government's plea offer, Islam Bey, her codefendant, may be a key witness at Ms. xxxxxxxx's motion hearing.
3. Counsel has contacted Diana Epps, Esq., the Assistant United States Attorney assigned to this case, and she has advised undersigned counsel that she has no opposition to the late-filing of the motion.
Therefore, counsel respectfully requests to be permitted to late-file the attached Suppression Motion.
Respectfully submitted,
A.J. KRAMER
FEDERAL PUBLIC DEFENDER
________________________
Valencia Rainey
Counsel for xxxxx. xxxxxxxx
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 Suppression Motion has been personally served upon the Office of the United States Attorney, 555 Fourth Street, N.W., Washington, D.C. 20001 this 12th day of September, 1997, for Assistant United States Attorney Diana Epps, 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