Unopposed Motion to Extend Time to File Responses — United States v. Meelad Dezfooli (Dkt. 157)

Summary

Defendant Meelad Dezfooli's Unopposed Motion to Extend Time to File Responses to the Government's Motions for Interlocutory Order of Sale, Case 2:22-cr-00142, Document 157, filed 05/14/24, District of Nevada; it is marked the Third Request. Counsel says the current deadline for all such Responses is May 17, 2024, and asks for an extension to and including May 24, 2024. Counsel states that more time is needed to research potential arguments and gather supporting evidence, and that Dezfooli is presently detained pending trial. Counsel also states that Assistant United States Attorney Hollingsworth had no objection and agreed. The signature line is /s/ Richard J. Pocker, Boies Schiller Flexner LLP; an IT IS SO ORDERED line is dated 5/14/2024.

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Case 2:22-cr-00142-RFB-DJA Document 157 Filed 05/14/24 Page1of4

BOIES SCHILLER FLEXNER LLP
RICHARD J. POCKER, ESQ.
Nevada Bar No. 3568

300 South Fourth Street, Suite 800
Las Vegas, Nevada 89101

Telephone (702) 382-7300

Email rpocker@bsfllp.com

Attorney for Defendant

MEELAD DEZFOOLI

UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

UNITED STATES OF AMERICA, 2:22-CR-142-RFB-DJA

Plaintiff, Defendant Meelad Dezfooli’s Unopposed
Motion to Extend Time to File Responses
V. to the Government’s Motions for
Interlocutory Order of Sale for (1) 1829 La
MEELAD DEZFOOLI, Calera Avenue, (2) 890 Harbor Avenue, (3)
6033 Watermelon Street, and (4) 6116
Defendant. Chinook Way (ECF Nos. 132, 133, 135,
136, respectively).

(Third Request)

This Motion to Extend Time is the third request for such relief. (Local Rule IA 6-1 of
the Local Rules of Practice for the U.S. District Court for the District of Nevada.)

Defendant MEELAD DEZFOOLI respectfully moves this Court for an Order
extending the time for him to file his Responses to the Government’s Motions for
Interlocutory Order of Sale for 1829 La Calera Avenue, 890 Harbor Avenue, 6033
Watermelon Street, and 6116 Chinook Way. The current deadline for all such Responses is
May 17, 2024. Defendant DEZFOOLI requests an extension to and including May 24, 2024,
in which to file its Responses.

Undersigned counsel met with Defendant DEZFOOLI, and has spoken with him
further to determine what positions he wishes to take concerning these motions and other
issues in this case. Nonetheless, counsel needs additional time to research potential
arguments and gather supporting evidence. Defendant DEZFOOLI’S presence in pretrial
custody and scheduling problems with the detention center at which he resides, have

complicated effective meetings in this complex case.
Case 2:22-cr-00142-RFB-DJA Document 157 Filed 05/14/24 Page 2 of 4

Defendant DEZFOOLI is presently detained pending trial and is consequently
separated from his business records and vital information necessary to oppose the
Government’s Motions. It is also extremely difficult to work on motion response preparation
in a complex white collar business case when the client is for all practical purposes unavailable
to readily assist counsel.

Assistant United States Attorney Hollingsworth and I communicated regarding the
requested extension of time. He had no objection and agreed to it. This Unopposed Motion
is not submitted solely for the purpose of delay or for any other improper purpose, but rather
to enable counsel to prepare Responses which reflect the client’s intentions.

For the foregoing reasons, Defendant DEZFOOLI requests an extension of time to
and including May 24, 2024, so as to allow Defendant DEZFOOLI and his counsel the
Responses he wishes to make to the motions.

DATED: May 13, 2024.

BOIES SCHILLER FLEXNER LLP

/s/ Richard J. Pocker
RICHARD J. POCKER, ESQ.

IT IS SO ORDERED:

RICHARD F. BOULWA8=—"”
UNITED STATES DISTRICT COURT JUDGE

DATED: 5/14/2024
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Case 2:22-cr-00142-RFB-DJA Document 157 Filed 05/14/24 Page 3 of 4

CERTIFICATE OF SERVICE

I certify that on this 13% day of May, 2024 service of Defendant DEZFOOLI’S Unopposed
Motion to Extend Time to File Responses to the Government’s Motions for Interlocutory
Order of Sale for (1) 1829 La Calera Avenue, (2) 890 Harbor Avenue, (3) 6033 Watermelon
Street, and (4) 6116 Chinook Way (ECF Nos. 132, 133, 135, 136, respectively). (Third
Request) via the United States District Court e-filing system was made on all of the parties that

have entered their appearances in this case.

/s/ Richard J. Pocker
An employee of Boies Schiller Flexner LLP
Case 2:22-cr-00142-RFB-DJA Document 157 Filed 05/14/24 Page 4 of 4

Karen D. Foster

From: Hollingsworth, Daniel (USANV) <Daniel.Hollingsworth@usdoj.gov>
Sent: Monday, May 13, 2024 2:34 PM

To: Karen D. Foster

Cec: Richard Pocker; Debra Burgos

Subject: RE: USA v. Dezfooli

| have no objection to this extension of time.
Thank you,

DDH.

From: Karen D. Foster <kdfoster@BSFLLP.com>

Sent: Monday, May 13, 2024 10:26 AM

To: Hollingsworth, Daniel (USANV) <DHollingsworth@usa.doj.gov>

Cc: Richard Pocker <rpocker@BSFLLP.com>; Debra Burgos <dburgos@BSFLLP.com>
Subject: [EXTERNAL] USA v. Dezfooli

Good morning, Dan. | called and left you a voice message earlier this morning requesting an extra week to respond
to the motions seeking interlocutory orders of sale in the Dezfooli case. Attached is a proposed Unopposed
Motion for purposes of effectuating such an extension.

Please advise as to the Government’s position on my request, so | can determine which variety of motion
for extension | must file.

Richard Pocker

Karen D. Foster
Receptionist

BOIES SCHILLER FLEXNER LLP

300 South Fourth Street, Suite 800
Las Vegas, Nevada 89101

(t) +1 702-382-7300

(f) +1 702-382-2755
kdfoster@bsfllp.com
www.bsfllp.com

The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain information that, among
other protections, is the subject of attorney-client privilege, attorney work product or exempt from disclosure under applicable law. If the reader of this electronic message is
not the named recipient, or the employee or agent responsible to deliver it to the named recipient, you are hereby notified that any dissemination, distribution, copying or other
use of this communication is strictly prohibited and no privilege is waived. If you have received this communication in error, please immediately notify the sender by replying to
this electronic message and then deleting this electronic message from your computer. [v.1 08201831BSF]


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