Opinion
Docket No.: 11cr768(JLL)
02-22-2012
U.S. v. Jovany Clermont
ANTHONY C. MACK* +
KELVIN R. GIL*
* NJ AND NY BARS
+ Admitted to US Supreme Court
MACK & GIL, LLC
Attorneys-At-Law
A Limited Liability Company
NEW YORK OFFICE
REPLY TO NJ OFFICE
VIA ECF
Hon. Jose L. Linares, U.S.D.J.
U.S. District Court-N.J.
50 Walnut Street
Newark, NJ 07102
Dear Judge Linares:
Please be advised that this office represents the above referenced defendant. An Order was entered by your Honor which requires defense motions to be filed by February 24, 2012.
I do intend on filing motions one of which is a Title III Motion to Suppress Intercepted Wire Transmissions. I just received the affidavits request the authorization to intercept the calls on February 21, 2012.
Thus, I am requesting an additional week to March 2, 2012 to file my motions and thereby extending the Government's time to respond to March 16, 2012.
I have the consent of my adversary AUSA Michael Robertson. Thank you for your anticipated concern and cooperation.
Respectfully,
__________________
Anthony C. Mack, Esq.
cc: Michael Robertson, AUSA (via ECF)