Opinion
Crim. No. 08-775 (FSH)
06-15-2012
LAW OFFICES OF TIMOTHY R. ANDERSON, LLC Timothy R. Anderson, Esq. Admitted to practice in NJ & MN
LAW OFFICES OF TIMOTHY R. ANDERSON, LLC
Timothy R. Anderson, Esq.
Admitted to practice in NJ & MN
The Hon. Faith S. Hochberg
United States District Judge
District of New Jersey
Request for Extension of Time to File Motion Dear Judge Hochberg:
This letter is to request an extension of time to file a motion for a new trial in Mr. Calloway's case. The motion currently is due by June 18, 2012, with the government's response due by July 9, 2012, and a possible defense reply due no later than July 14, 2012. I request an extension of approximately three weeks. The additional time should give me adequate time to complete my evaluation of the possible issues, gather any relevant information, meet additionally with Mr. Calloway, and complete the necessary research and draft the motion. Ultimately, an extension of time to file would be in the interests of justice.
I propose the following revised schedule: that Defendant may file a motion for a new trial by July 11, 2012, the government may respond by August 1, 2012, and a reply may be filed not later than August 8, 2012. I communicated late yesterday with Assistant U.S. Attorney Rob Frazer and he has no objection to this request.
On behalf of Mr. Calloway, thank you for your time and thought devoted to this request. Please contact me if you have any questions or concerns.
Respectfully submitted,
Timothy R. Anderson
Timothy R. Anderson
cc: Rob Frazer, Asst. U.S. Atty (by Email and ECF)
Sadiq Calloway