Opinion
1:19-cr-437-AKH-2
09-13-2022
UNITED STATES OF AMERICA, v. MARC LAWRENCE, Defendant.
MOTION FOR EXTENSION OF TIME TO RESPOND TO GOVERNMENT RESPONSE TO MOTION FOR REDUCTION OF SENTENCE
I, Marc Lawrence, defendant herewith, move under to 18 U.S.C. § 3582(c)(1)(A)(i) that this Court grant me an additional two weeks from Friday, September 2, 2022, to respond to the Government's response to my Motion for Reduction of Sentence Pursuant to 18 U.S.C. § 3582(c)(1)(A).
I have been informed by family friends that the Government filed a response to my pending Motion for Reduction of Sentence Pursuant to 18 U.S.C. § 3582(c)(1)(A) three weeks ago. I further understand that the Court has set September 2, 2022, as the deadline for my reply filing.
However, I have not received a copy of the Government response in the mail. I was able to contact the Court's clerk, and on August 31, Stanley Klimek, a Records/Reproduction Clerk, reported that the response was filed on August 12, 2022, and should have been mailed to me.
I have arranged to obtain a copy from a third party, but I have not received the copy as of the date of filing of this Motion. Thus, I request that my deadline for filing a reply be extended to September 16, 2022, to provide an additional two weeks.
The non-delivery of the Government response provides good cause for grant of this motion.
WHEREFORE, this Motion should be granted, and I should be permitted to reply to the Government's response by the close of business September 16, 2022. The statements of fact made herein are true, under penalty of perjury.