Joint MOTION for Extension of Time to File… — Joint MOTION for Extension of Time to File Pretrial motions and… (Dkt. 40)

Summary

Application for Extension of Time for Deadlines in Scheduling Order (DE 27), Document 40, dated July 10, 2024 in United States of America against Eric Rivera, Adrienne Ponzo, and James Wessels, Crim. No. 24-267 (KMW) (D.N.J.). It asks for an order extending by two months the time for Eric Rivera to file pretrial motions and the dates for responses, replies, oral argument and the final pretrial conference. It states that no previous extension has been obtained, that the current time to file pretrial motions expires on July 13, 2024, and that Rivera's counsel, Philip L. Reizenstein, was recently retained and is awaiting receipt of discovery. It says counsel for co-defendants Ponzo and Wessels wish to join, and that AUSA Daniel Friedman has no objection. Reizenstein signs with S/.

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1 
========================================================================= 
UNITED STATES DISTRICT COURT 
DISTRICT OF NEW JERSEY 
========================================================================= 
UNITED STATES OF AMERICA 
Crim. No. 24-267 (KMW) 
 
against 
APPLICATION FOR EXTENSION OF TIME   
FOR DEADLINES IN  
  
SCHEDULING ORDER (DE 27) 
 
 
ERIC RIVERA, 
ADRIENNE PONZO, and 
JAMES WESSELS 
Defendant 
 
 
Application is hereby made for an Order extending time within which Defendant Eric Rivera 
may file Pretrial Motions and extending dates requiring subsequent responses, replies, oral argument, 
and final pretrial conference by two months and it is represented that: 
 
1. 
No previous extension has been obtained; 
 
 
2. 
The current time to file pretrial motions expires on July 13, 2024; 
 
3. 
Undersigned counsel for Eric Rivera – Philip L. Reizenstein, Esq. – was recently 
retained and pursuant to the Scheduling Order, has mailed to Counsel for the United States two USB 
hard drives for discovery and is awaiting receipt of discovery;  
 
4. 
Defense Counsel for co-defendants Adrienne Ponzo and James Wessels – Mark 
Catanzaro, Esq. and Troy Archie, Esq. – have indicated they wish to join this Application for Extension 
of Time for Deadlines in Scheduling Order (DE 27) by two months; and 
 
5. 
Counsel for the United States, AUSA Daniel Friedman, has indicated he has no 
objection to this application. 
Dated: July 10, 2024 
Respectfully submitted,  
S/Philip L. Reizenstein 
Philip L. Reizenstein, Esq. 
Florida Bar# 634026 
2828 Coral Way 
Suite 540 
Case 1:24-cr-00267-KMW     Document 40     Filed 07/10/24     Page 1 of 2 PageID: 247

 
 
2 
Miami, FL, 33145 
(305) 444-0755 
Philreizenstein@protonmail.com 
 
 
Case 1:24-cr-00267-KMW     Document 40     Filed 07/10/24     Page 2 of 2 PageID: 248

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