Unopposed Motion for Extension of Time to respond to defendant's motions — USA v. Sheppard (Dkt. 206, S.D. Fla.)

Record facts

U.S. District Court for the Southern District of Florida · No. 1:22-cr-20290-BB · Doc. 206 · 2024-02-09 · Docket on CourtListener

Full text

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
 
Case No. 22-20290-CR-BLOOM(s) 
 
UNITED STATES OF AMERICA  
 
 
 
vs. 
 
 
 
 
 
 
 
 
 
 
ERIC DEAN SHEPPARD 
 
 
 
       Defendant. 
                                    / 
 
 
UNITED STATES’ MOTION FOR EXTENSION OF TIME 
TO FILE GOVERNMENT’S RESPONSE TO DEFENDANT’S 
MOTION FOR JUDGMENT OF ACQUITAL AND  
DEFENDANT’S MOTION FOR NEW TRIAL 
 
 
The United States, by and through the undersigned Assistant United States Attorney, 
respectfully moves this Court for a one-week extension of time to respond to the defendant’s 
motion for judgment of acquittal and motion for new trial.  In support thereof, the government 
states as follows: 
1. 
A jury verdict was returned in this case on Friday, January 12, 2024.  Following 
the jury’s verdict, the defense advised the Court that it was renewing its motion for judgment of 
acquittal.  At that time, the Court gave the defendant one week to file his motion for judgment of 
acquittal and gave the government one week to file its response. 
2. 
Thereafter the defendant twice moved for one-week extensions of time to file his 
motion or motions, which the Court granted.  On Friday, February 2, 2024, the defendant filed a 
motion for judgment of acquittal and a motion for new trial. 
3. 
Should the government’s response to the motion for judgment of acquittal still be 
due within a week of the defendant’s filing, the government’s response would be due today, 
Case 1:22-cr-20290-BB   Document 206   Entered on FLSD Docket 02/09/2024   Page 1 of 3

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February 9, 2024.  The government requests the full ten (10) days that it would normally have 
under the Local Rules to respond to the defendant’s motion for judgment of acquittal, and requests 
that the government’s response to the motion for judgment of acquittal be due on Friday, February 
16, 2024. 
4. 
Regarding the government’s response to the defendant’s motion for new trial, the 
government’s response is due Friday, February 16, 2024.   
5. 
The undersigned AUSA has multiple doctor’s appointments during the week of 
February 12th, which appointments were rescheduled from November and December of 2023.  
The undersigned AUSA also has other case obligations and is planning to take a couple of vacation 
days around the President’s Day holiday.  As a result, the government requests one additional 
week to file its response to the motion for new trial, which would be due on Monday, February 26, 
2024. 
6. 
The undersigned AUSA conferred with counsel for the defendant, who indicated 
that the defendant has no objection to the government’s request. 
7. 
This motion is made for good cause and not for the purpose of causing any undue 
delay in this case.   
 
For the reasons set forth above, the United States respectfully requests that the Court grant 
the United States a one-week extension of time as to each of the defendant’s motions:  motion for  
 
 
Case 1:22-cr-20290-BB   Document 206   Entered on FLSD Docket 02/09/2024   Page 2 of 3

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judgment of acquittal and motion for new trial. 
             
 
 
 Respectfully submitted, 
    
MARKENZY LAPOINTE 
  
 
UNITED STATES ATTORNEY 
 
By:    s/Aimee Jimenez___________  
 
 
 
 
 
 
 
Aimee C. Jimenez 
 
 
 
 
 
 
Assistant United States Attorney 
 
 
 
 
 
 
Court No. A5500795 
 
 
 
 
 
 
99 Northeast 4th Street 
 
 
 
 
 
 
Miami, Florida 33132-2111 
 
 
 
 
 
 
Tel: (305) 961-9028 
 
 
 
 
 
 
Email: aimee.jimenez@usdoj.gov  
 
 
 
 
 
CERTIFICATE OF SERVICE 
 
I HEREBY CERTIFY that on February 9, 2024, I electronically filed the foregoing  
motion and proposed order with the Clerk of the Court using CM/ECF.     
s/Aimee Jimenez____________                           
 
 
 
 
 
 
Aimee C. Jimenez 
 
 
 
 
 
 
  Assistant United States Attorney 
 
Case 1:22-cr-20290-BB   Document 206   Entered on FLSD Docket 02/09/2024   Page 3 of 3

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