USA v. LaBrecqueOppositionD. Mass.April 21, 2005UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS UNITED STATES OF AMERICA ) ) v. ) Criminal No. 03-10381-NG ) MARY ELLEN LABRECQUE, ) a/k/a ELLEN LABRECQUE, ) ) Defendant. ) GOVERNMENT’S OPPOSITION TO DEFENDANT’S MOTION FOR LEAVE TO FILE MOTIONS The United States of America, by Michael J. Sullivan, United States Attorney, and B. Stephanie Siegmann, Assistant United States Attorney for the District of Massachusetts, hereby opposes Defendant’s Motion for Leave to File Motions on two grounds. First, the time to file discovery motions and a motion for a bill of particulars has expired. See L.R. 116.3(A)(discovery motions must be filed within 42 days of arraignment); Fed. R. Crim. P. 7(f) (“The defendant may move for a bill of particulars before or within 10 days after arraignment . . .”). Additionally, the Defendant failed to wait fourteen days after serving its written requests on the Government to file its motions in violation of Local Rule 116.3(E). For these reasons, the Defendant’s Motion for Leave to File its Discovery Motion and Motion for a Bill of Particulars should be denied. Respectfully submitted, MICHAEL J. SULLIVAN United States Attorney By: /s/ B. Stephanie Siegmann B. Stephanie Siegmann Assistant U.S. Attorney Dated: April 21, 2005 Case 1:03-cr-10381-NG Document 47 Filed 04/21/2005 Page 1 of 2 CERTIFICATE OF SERVICE I do hereby certify that a copy of foregoing opposition was served upon the counsel listed below by electronic notice on this 21st day of April 2005: Max D. Stern, Esq. /s/ B. Stephanie Siegmann B. Stephanie Siegmann Assistant U.S. Attorney Case 1:03-cr-10381-NG Document 47 Filed 04/21/2005 Page 2 of 2
