IN THE UNITED STATES DISTRICT COURT FOR

THE DISTRICT OF COLUMBIA CIRCUIT



UNITED STATES OF AMERICA :

:

v : CRIM. NO. 9x-xxx (TFH)

:

xxxxxxx xxxxxxxxxxx, :

:

Defendant. :

______________________________:



MOTION FOR LEAVE TO LATE-FILE PRETRIAL MOTIONS



xxxxxxx xxxxx, through counsel, respectfully moves the court for leave to late-file the attached Motion to Suppress Tangible Evidence.

As grounds for this Motion, Mr. xxxxxxxx, through counsel, states:

1. Mr. xxxxxxxx was arrested on November 14, 1997, and was arraigned on December 18, 1997 before the Honorable Thomas F. Hogan. The court ordered defense motions to be filed by .

2. Undersigned counsel was unable to file the attached motions by the due date because of prior commitments.

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 Percy G. xxxxxxxx.



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 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

















IN THE UNITED STATES DISTRICT COURT FOR

THE DISTRICT OF COLUMBIA CIRCUIT



UNITED STATES OF AMERICA :

:

v : CRIM. NO. xx-xxx (TFH)

:

PERCY G. xxxxxxxx, :

:

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.









THOMAS F. HOGAN

UNITED STATES DISTRICT JUDGE





Copies To:



Valencia Rainey, Esq.

Assistant Federal Public Defender

625 Indiana Avenue N.W.

Washington, D.C. 20004



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