First Motion for Extension of Time to File Defendant's — United States v. Lewis Reed (Dkt. 87, E.D. Mo.)

Summary

A first motion to extend the time to file the defendant's objections to the Presentence Investigation Report, filed November 15, 2022 as Doc. 87 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 the court to extend the time to file his objections by seven days. The motion states that counsel received the report on November 1, began a trial on November 2, and first spoke with the defendant about it the previous week, so more time is needed to review it together. It is signed /s/ by Adam D. Fein as attorney for the defendant, with service on Assistant United States Attorney Hal Goldsmith.

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Full text

 Case: 4:22-cr-00297-SRC Doc. #: 87 Filed: 11/15/22 Page: 1 of 2 PageID #: 449




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

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

FIRST MOTION TO EXTEND THE TIME TO FILE DEFENDANT’S OBJECTIONS TO
              THE PRESENTENCE 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 mid last week.

       3.      As a result, Defendant and counsel need a brief amount of additional time to

               review the PSR together and to file any objections thereto.

       WHEREFORE, Defendant respectfully requests this Court to extend the time to file his

objections to the Presentence Investigation Report by seven days.




                                                 1
 Case: 4:22-cr-00297-SRC Doc. #: 87 Filed: 11/15/22 Page: 2 of 2 PageID #: 450




                                             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 15, 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.




                                                2


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