Opinion
Criminal No. 12-73 (JL)
05-08-2012
United States v. Joseph Belasco
ARSENEAULT, WHIPPLE, FASSETT & AZZARELLO, LLP JACK ARSENEAULT JOHN C. WHIPPLE[sup *] DAVID W. FASSETT JOHN A. AZZARELLO.[sup +] ATTORNEYS AT LAW THOMAS M. LENNEY[sup ++] ADALGIZA A. NUNEZ[sup +] JOHN J. ROBERTS[sup +]
ARSENEAULT, WHIPPLE, FASSETT & AZZARELLO, LLP
JACK ARSENEAULT
DAVID W. FASSETT
CERTIFIED BY THE SUPREME COURT OF NEW JERSEY AS A CRIMINAL TRIAL ATTORNEY
*ALSO ADMITTED IN WASHINGTON, DC
ATTORNEYS AT LAW
THOMAS M. LENNEY
ADALGIZA A. NUNEZ
JOHN J. ROBERTS
ELECTRONICALLY FILED
Honorable Jose L. Linares, U.S.D.J.
Martin Luther King, Jr. U.S. Courthouse
Dear Judge Linares:
We represent Defendant. By Complex Case Order filed February 27, 2012 [Doc. 8], the Court prescribed the following schedule: defense motions on the indictment due May 14, 2012; Government's response due June 11, 2012; trial date tentatively set for September 12, 2012.
We inspected the Government's discovery materials on March 20, 2012 and requested copies of certain materials produced. We also requested that the Government obtain and produce certain other materials from the alleged victim. The Government has provided us with copies of certain materials and has agreed to produce the other materials as soon as they become available. The Government anticipates receiving and producing a significant number of such materials by the end of next week.
In light of the foregoing, the parties hereby jointly request that the Court extend the foregoing dates by at least sixty (60) days.
Thank you for considering this request.
Respectfully,
David W. Fassett cc: V. Grady O'Malley, AUSA
John A. Azzarello, Esq.
Joseph Belasco