USA v. Carpenter

MOTION for Leave to File Reply Memoranda as to Daniel E. Carpenter.

D. Mass.September 16, 2005

UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS ____________________________________ ) UNITED STATES OF AMERICA ) ) v. ) CRIMINAL NO. 04-10029-GAO ) DANIEL E. CARPENTER ) ____________________________________) Motion for Leave to File Reply Memoranda Now comes the Defendant, by and through undersigned counsel, pursuant to Local Rule 7.1(B)(3), and hereby moves the Court for leave to file, on or before Monday, September 26, 2005, memoranda in reply to the government’s oppositions to the defendant’s motions pursuant to Rules 29 and 33 of the Federal Rules of Criminal Procedure. The government’s responsive pleadings are premised on a profound misapprehension of the relevant facts and law. Wherefore, especially given the gravity of the interests at stake to the defendant, the defendant seeks leave to file reply memoranda on or before September 26, 2005. DANIEL E. CARPENTER, By his attorney, /s/ Robert M. Goldstein Robert M. Goldstein Mass. Bar No. 630584 20 Park Plaza, Suite 903 Boston, MA 02116 (617) 742-9015 rmg@goldstein-lawfirm.com Dated: September 16, 2005 Case 1:04-cr-10029-GAO Document 176 Filed 09/16/2005 Page 1 of 1