Opinion
NO. 3:09-cr-00036
11-13-2012
UNITED STATES OF AMERICA, v. JAMES J. LANG
JERRY E. MARTIN United States Attorney for the Middle District of Tennessee S. Carran Daughtrey Assistant U.S. Attorney
JUDGE HAYNES
MOTION FOR LEAVE TO FILE LATE RESPONSE TO
DEFENDANT'S MOTION FOR A MITIGATED SENTENCE AND VARIANCE
BELOW THE SENTENCING GUIDELINES
The United States of America, by and through S. Carran Daughtrey, Assistant United States Attorney for the Middle District of Tennessee, hereby requests that this Court allow the government to file late a sentencing memorandum in this case. The undersigned attorney recognizes that this Court has many cases and very little time to review late filings, and apologizes for this late filing. As grounds for this motion, the undersigned attorney notes that she has had an ongoing family emergency that has resulted in the undersigned's lengthy and unexpected time away from the office for the last two months and working diligently to catch up. Thus, the government respectfully requests that this Court permit the late filing of the previously filed response to defendant's Motion for a Mitigated Sentence and Variance below the Sentencing Guidelines. (R. 72: Motion).
Respectfully submitted,
JERRY E. MARTIN
United States Attorney for the
Middle District of Tennessee
______________________
S. Carran Daughtrey
Assistant U.S. Attorney