MOTION for Extension of Time to File Response/Reply… — MOTION for Extension of Time to File Response/Reply as… (Dkt. 81)

Record facts

U.S. District Court for the District of New Jersey · No. 1:24-cr-00267-KMW · Doc. 81 · 2025-07-22 · Docket on CourtListener

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UNITED STATES DISTRICT COURT 
DISTRICT OF NEW JERSEY 
========================================================================= 
UNITED STATES OF AMERICA 
Crim. No. 24-267 (KMW) 
 
against 
 APPLICATION FOR EXTENSION  OF TIME 
FOR DEFENDANT TO OBTAIN NEW 
COUNSEL 
 
 
ERIC RIVERA, 
ADRIENNE PONZO, and 
JAMES WESSELS 
Defendant 
 
 
Application is hereby made on behalf of Eric Rivera for an Order extending for sixty days the 
time period for Eric Rivera to obtain new counsel. In support thereof, the defendant avers the following:  
 
1. The Court previously granted the undersigned attorney’s motion to withdraw. [DE 78] The 
order on withdrawal became effective on July 22, 2025, when Mr. Rivera obtained new 
counsel. Until that time the Court directed the undersigned attorney to remain on the case to 
protect Mr. Rivera’s interests and assist him in any communications with the Court, or 
responses to any issues that could arise before new counsel was obtained.  
2. The undersigned attorney received the following from Mr. Rivera with a request that he file 
this with the court, which is now being done. Counsel will inform Mr. Rivera of the Court’s 
decision on this request.  
3. The following is an exact copy of the email sent to counsel that Mr. Rivera requested be 
presented to the court:  
 
Dear Judge Williams, 
I am writing to respectfully request an extension of sixty (60) business days to secure new 
legal counsel in the above-referenced matter. 
As Your Honor suggested during our previous court proceeding, I am seeking additional 
time to hire new counsel to properly represent my interests in this case. I am actively 
working to identify and retain qualified legal representation, but require additional time to: 
•Review my case materials with prospective counsel and complete the necessary retainer 
Case 1:24-cr-00267-KMW     Document 81     Filed 07/16/25     Page 1 of 2 PageID: 537

 
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fee agreement.  
I understand the importance of moving this matter forward in a timely manner and do not 
make this request lightly. However, securing competent representation is essential to ensure 
the proper administration of justice and protect my legal rights. 
I respectfully request that the Court grant this extension and adjust any upcoming deadlines 
accordingly. I am prepared to appear at any hearing Your Honor deems necessary regarding 
this request. 
Thank you for your consideration of this matter. I look forward to your response. 
Respectfully submitted, 
Mr. Eric Rivera  
 
4.  Counsel for the United States, AUSA Daniel Friedman was not available due to a notice 
on his email that he is on extended leave.   
Dated: July 16, 2025.  
Respectfully submitted,  
S/Philip L. Reizenstein 
Philip L. Reizenstein, Esq. 
Florida Bar# 634026 
2828 Coral Way 
Suite 540 
Miami, FL, 33145 
(305) 444-0755 
Philreizenstein@protonmail.com 
 
 
Case 1:24-cr-00267-KMW     Document 81     Filed 07/16/25     Page 2 of 2 PageID: 538

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