Amended Motion for Extension of Time to File Defendant's — United States v. Lewis Reed (Dkt. 92, E.D. Mo.)

Summary

A first amended motion to extend the time to file the defendant's objections to the Presentence Investigation Report, filed November 17, 2022 as Doc. 92 in United States v. Lewis Reed, Case No. 4:22-cr-297-2-SRC, in the U.S. District Court for the Eastern District of Missouri, Eastern Division. Through counsel, Reed asks for seven more days. The motion states that the defendant does not expect to file any objections but wants time to discuss the report further with counsel and to make sure any objections are filed within the court's time frame. It states that Assistant United States Attorney Hal Goldsmith does not object, and it is signed /s/ by Adam D. Fein as attorney for the defendant.

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 Case: 4:22-cr-00297-SRC Doc. #: 92 Filed: 11/17/22 Page: 1 of 2 PageID #: 459




                          IN THE UNITED STATES DISTRICT COURT
                              ESTERN DISTRICT OF MISSOURI
                                    EASTERN DIVISION

UNITED STATES OF AMERICA,                        )
                                                 )
       Plaintiff,                                )
                                                 )
v.                                               ) Case No.: 4:22-cr-297-2-SRC
                                                 )
LEWIS REED,                                      )
                                                 )
            Defendants.                          )

     FIRST AMENDED MOTION TO EXTEND THE TIME TO FILE DEFENDANT’S
          OBJECTIONS TO THE PRESETENCE INVESTIGATION REPORT

       COMES NOW Defendant, Lewis Reed, by and through counsel, and hereby moves this

Court to extend the time to file his objections to the Presentence Investigation Report by seven

days. In support of this motion, Defendant states as follows:

       1.      Counsel received Defendant’s Presentence Investigation Report (PSR) on

               November 1.

       2.      Counsel began a trial on November 2 and first spoke with Defendant about the

               PSR late last week.

       3.      Defendant does not expect to file any objections to the PSR but asks for a brief

               amount of additional time to (1) discuss the PSR further with counsel and (2)

               ensure that any objections that do arise are not filed outside the time frame set by

               this Court.

       4.      Defendant, through counsel, has discussed this matter with Assistant United

               States Attorney Hal Goldsmith.

       5.      Mr. Goldsmith does not object to Defendant’s request.

       WHEREFORE, Defendant respectfully requests this Court to extend the time to file his
 Case: 4:22-cr-00297-SRC Doc. #: 92 Filed: 11/17/22 Page: 2 of 2 PageID #: 460




objections to the Presentence Investigation Report by 7 days.




                                             Respectfully submitted,

                                     By:     /s/ Adam D. Fein

                                             Adam D. Fein, # 52255 MO
                                             Attorney for Defendant
                                             120 S. Central Avenue, Suite 130
                                             Clayton, Missouri 63105
                                             (314) 862-4332
                                             afein@rsflawfirm.com




                                CERTIFICATE OF SERVICE

       I hereby certify that on November 17, 2022, the foregoing was electronically filed with
the Clerk of the Court to be served by operation of the Court’s electronic filing system upon Mr.
Hal Goldsmith, Assistant United States Attorney.


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