Opinion
No. 3:11-00204-1
08-22-2012
UNITED STATES OF AMERICA v. MANILA VICHITVONGSA a/k/a MANEE VICHITVONGSA
RONALD C. SMALL (BPR #023150) Assistant Federal Public Defender Attorney for Manila Vichitvongsa
JUDGE TRAUGER
MOTION FOR EXTENSION OF TIME TO FILE AGREED JURY INSTRUCTIONS,
ALTERNATIVE JURY INSTRUCTIONS AND VERDICT FORMS
The defendant, Manila Vichitvongsa, through counsel, respectfully moves this Honorable Court for an extension of time, until close of business Thursday, August 23, 2012, in which to file agreed jury instructions, alternative jury instructions and verdict forms. Trial is set for August 28, 2012. By order dated April 3, 2012, (Docket No. 43), this Court set a deadline of not later than close of business on Tuesday, August 21, 2012, for the parties to file agreed jury instructions, alternative jury instructions and agreed or alternative verdict forms. An extension is required because counsel requires additional time to discuss the proposed jury instructions in an effort to reach an agreement. The parties will then be in a position to file agreed jury instructions, and any alternative/additional jury instructions, if necessary.
Accordingly, it is respectfully requested that the Court grant an extension until close of business on Thursday, August 23, 2012, in which to file agreed or alternative jury instructions and verdict forms.
Respectfully submitted,
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RONALD C. SMALL (BPR #023150)
Assistant Federal Public Defender
Attorney for Manila Vichitvongsa