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