Unopposed Motion for Extension of Time to File Post-Trial Motions — USA v. Sheppard (Dkt. 181, S.D. Fla.)

Record facts

U.S. District Court for the Southern District of Florida · No. 1:22-cr-20290-BB · Doc. 181 · 2024-01-12 · Docket on CourtListener

Full text

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FORIDA 
CASE No. 22-20290-CR-BLOOM/OTAZO-REYES 
 
UNITES STATES OF AMERICA, 
 
Plaintiff,  
v.  
ERIC DEAN SHEPPARD, 
 
Defendant. 
____________________________________/ 
UNOPPOSED MOTION FOR 
EXTENSION OF TIME TO FILE POST-TRIAL MOTIONS 
 
Defendant Eric Dean Sheppard respectfully submits this Unopposed Motion for Extension 
of Time to post-trial motions, and in support states: 
1. 
At the conclusion of trial today, the Court ordered post-trial motions to be filed by 
January 19. 
2. 
Defense counsel respectfully requests an additional 7 days to file post-trial motions. 
Undersigned counsel is required to be in Houston, Texas in the Southern District of Texas on 
January 16 and January 17, 2024, for a sentencing. In addition to travel and attending the 
sentencing itself, undersigned counsel must also prepare for the sentencing between now and 
January 16.  
3. 
The above-referenced sentencing in Houston has already been postponed several 
times, including twice related to the trial of this matter, and cannot be put off again. 
4. 
In addition, there is an extensive amount of work to be done for post-trial motions, 
and additional time would be needed on its own, independent of the scheduling conflict. 
5. 
The requested extension is not sought for purposes of delay. 
Case 1:22-cr-20290-BB   Document 181   Entered on FLSD Docket 01/12/2024   Page 1 of 2

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6. 
The requested extension will not prejudice either party. 
7. 
Counsel for the Government has no objection to the relief sought. 
For the foregoing reasons, Defendant respectfully requests a 7-day extension of time, until 
January 26, 2024, to file post-trial motions in this matter, and for any other relief the Court deems 
just and proper. 
Dated: January 12, 2024. 
 
 
 
Respectfully submitted,  
NELSON MULLINS  
One Biscayne Tower, 21st Floor  
2 S. Biscayne Boulevard  
Miami, FL 33131  
Telephone: 305.373.9400  
By: /s/ Christopher Cavallo 
Jayne C. Weintraub 
Florida Bar No. 320382 
Jonathan Etra  
Florida Bar No. 686905 
Christopher Cavallo  
Florida Bar No. 0092305 
 
 
CERTIFICATE OF SERVICE 
 
I HEREBY CERTIFY that on January 12, 2024, the foregoing document was filed via the 
Court’s CM/ECF system to all counsel of record.  
/s/ Christopher Cavallo  
Christopher Cavallo 
Case 1:22-cr-20290-BB   Document 181   Entered on FLSD Docket 01/12/2024   Page 2 of 2

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