NO. CR.S-11-428 GEB
MARK J. REICHEL, Bar #155034 REICHEL & PLESSER L.L.P. Attorneys At Law Attorney for Defendant BRYAN SMITH
MARK J. REICHEL, Bar #155034
REICHEL & PLESSER L.L.P.
Attorneys At Law
Attorney for Defendant
REQUEST AND DECLARATION OF
DEFENSE COUNSEL TO FILE
DEFENDANT'S REPLY PLEADINGS
ON FRIDAY, JUNE 29, 2012
HEARING DATE REMAINS THE SAME
Judge: Hon. Garland E. Burrell Jr.
Defendant Bryan Smith, through counsel, hereby requests to file his Reply pleadings to the motions on file on June 29, 2012.
The Reply pleadings are currently due June 26, 2012.
Defense counsel submits the following in support:
The Motions are extensive, and the government and defense counsel both have previously been allowed additional time within which to file and Oppose the pleadings. Defense counsel was out of town June 11-18th, and returned to a very large and dispositive motion in a civil trial in Sacramento Superior Court having been filed in Weinrick v. Snyder, 34-2010-00071233. This motion, unexpected, has caused defense counsel to spend at least 3 days this week drafting the opposition. As well, defense counsel has extensive pleadings due in several federal criminal matters, and has had unexpected difficulty in getting the Reply pleadings on file in this case.
The delay was unexpected.
Defense counsel has contacted AUSA Rick Bender on two occasions, via e mail, and requested his agreement to this new date. I have not heard back from him.
I declare to the court that the foregoing is true and correct.
MARK J. REICHEL
It Is So Ordered. Reply Pleadings in this case shall be on file June 29, 2012.
GARLAND E. BURRELL, JR.
United States District Judge