Amended MOTION for Extension of Time to File… — Amended MOTION for Extension of Time to File Response/Reply… (Dkt. 82)

Record facts

U.S. District Court for the District of New Jersey · No. 1:24-cr-00267-KMW · Doc. 82 · 2025-07-22 · Docket on CourtListener

Full text

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UNITED STATES DISTRICT COURT 
DISTRICT OF NEW JERSEY 
========================================================================= 
UNITED STATES OF AMERICA 
Crim. No. 24-267 (KMW) 
 
against 
AMENDED  APPLICATION FOR 
EXTENSION  OF TIME FOR DEFENDANT 
TO OBTAIN NEW COUNSEL 
 
 
ERIC RIVERA, 
ADRIENNE PONZO, and 
JAMES WESSELS 
Defendant 
 
 
An Amended 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 
Case 1:24-cr-00267-KMW     Document 82     Filed 07/16/25     Page 1 of 2 PageID: 539

 
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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 
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 responded and requested that the 
defense inform the court that the Government objects:   
 
The Government objects to the requested extension of time for Mr. Rivera 
to retain counsel.  Since this matter was charged two years ago, Rivera has 
frequently delayed the proceedings by not engaging with his attorneys and 
by failing to timely retain new attorneys when provided ample time and 
opportunity to do so.  In order to assess the appropriate next steps and to 
properly balance the interests of justice in a speedy trial with Rivera’s Sixth 
Amendment rights, the Court should require Rivera to appear at the 
scheduled July 22, 2025 status conference and place on the record details 
of his efforts to retain counsel during the previous eight weeks   
 
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 82     Filed 07/16/25     Page 2 of 2 PageID: 540

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