Unopposed Motion for Extension of Time to File Post-Trial Reply Briefs — USA v. Sheppard (Dkt. 216, S.D. Fla.)

Record facts

U.S. District Court for the Southern District of Florida · No. 1:22-cr-20290-BB · Doc. 216 · 2024-02-28 · 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. 
____________________________________/ 
UNUPPOSED MOTION FOR EXTENSION OF TIME 
TO FILE POST-TRIAL MOTION REPLY BRIEFS AND FOR PAGE LIMIT INCREASE 
 
Defendant Eric Dean Sheppard respectfully submits this Motion for Extension of Time to 
File Replies in Support of Post-Trial Motions and for Page Limit Increase. In support, Defendant 
states: 
1. 
Trial in this matter ended January 12, 2024. 
2. 
On February 2, 2024, Defendant filed his motion for new trial [D.E. 204] and 
motion for acquittal [D.E. 205] (together, the “Post-Trial Motions”). 
3. 
Before filing its responses, the government sought and obtained leave to file an 
additional 5-7 pages for its response briefs. [D.E. 212; D.E. 213]. 
4. 
The government filed its responses to the Post-Trial Motions on February 23 and 
26, 2024. [D.E. 214; D.E. 215]. As such, Defendant’s replies in support of the Post-Trial Motions 
are due on March 1 and March 4, 2024. 
5. 
Several of Defendant’s counsel are travelling out of state for work-related matters 
over the next two weeks and are periodically unavailable up to and through the current reply 
deadlines. For this reason, as well as the number and complexity of issues that must be addressed 
Case 1:22-cr-20290-BB   Document 216   Entered on FLSD Docket 02/28/2024   Page 1 of 3

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in post-trial briefing, Defendant respectfully requests until March 11, 2024 to file his reply in 
support of his motion for acquittal, and until March 13, 2024 to file his reply in support of his 
motion for new trial.  
6. 
This extension is not sought for purposes of delay and will not prejudice any party. 
Sentencing in this matter is not scheduled until May 8, 2024. [D.E. 211]. 
7. 
Defendant also requests an additional 5-7 pages for his reply briefs in support of 
the Post-Trial Motions—the same page extension the government received, without objection, for 
its responses. The government’s response briefs raise numerous issues and arguments that 
Defendant needs more space to properly respond to and address.  
8. 
Undersigned counsel met and conferred with counsel for the United States, who 
advised that the government does not object to the relief sought herein. 
WHEREFORE, Defendant respectfully requests: (1) an extension until March 11, 2024, to 
file his reply in support of his motion for acquittal; (2) an extension until March 13, 2024, to file 
his reply in support of his motion for new trial; and (3) for an additional 5-7 pages for each of these 
reply briefs. 
Dated: February 28, 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 
 
Case 1:22-cr-20290-BB   Document 216   Entered on FLSD Docket 02/28/2024   Page 2 of 3

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CERTIFICATE OF SERVICE 
 
I HEREBY CERTIFY that on February 28, 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 216   Entered on FLSD Docket 02/28/2024   Page 3 of 3

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