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Unopposed Motion to Extend Deadline — No. 8:22-cr-00125 (Dkt. 172, D. Neb.)

Summary

Unopposed Motion to Extend Deadline, Doc 172 in Case 8:22CR125 in the District of Nebraska, filed 11/06/23 by the Acting United States Attorney through an Assistant U.S. Attorney in a multi-defendant case. The government asks for a short extension of the pretrial motion deadline of November 6, 2023, by approximately three to four weeks as to all defendants without a plea date, because defence counsel for each defendant have indicated a realistic possibility of resolving the charges short of further litigation. It asks that the intervening time be excluded under 18 U.S.C. 3161(h)(7) and, if the motion is denied, that the Court hold a pretrial conference under Rule 17.1 before setting trial, given the complex and wide-ranging nature of the case. A certificate of service is dated November 6, 2023.

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Cite this document

“Unopposed Motion to Extend Deadline — No. 8:22-cr-00125 (Dkt. 172, D. Neb.).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/unopposed-motion-to-extend-deadline-no-8-22-cr-00125-dkt-172-d-neb-20c73a4560/, SHA-256 0afbf7abf3ed4314f1c28a396162c8dbc3ced267187d81d0d523384f5f6399fb.

Full text

  8:22-cr-00125-BCB-MDN Doc # 172 Filed: 11/06/23 Page 1 of 2 - Page ID # 437




                         IN THE UNITED STATES DISTRICT COURT
                             FOR THE DISTRICT OF NEBRASKA

UNITED STATES OF AMERICA,

                       Plaintiff,

       vs.
                                                                        8:22CR125
RAMEL D. THOMPSON, CARL ESTWICK,
JACKIE HARPER, TARYSH G. HOGUE,                          UNOPPOSED MOTION TO EXTEND
RICHARD L. KELLY, LENFIELD                                       DEADLINE
KENDRICK, HENRY T. LEWIS, MICHAEL
A. PERKINS, and MICHAEL A. PERKINS,
JR.,

                       Defendants.


       COMES NOW Plaintiff United States of America and requests this Court grant a short

extension of the pretrial motion deadline from November 6, 2023 so the parties may attempt to

reach resolutions short of litigation. In support of this Motion, Plaintiff submits the following.

       1.      Undersigned counsel has continued to confer by email, phone and in person with

counsel for all the Defendants captioned above, in efforts to resolve pending charges short of

litigation. Each defense counsel has indicated there is a realistic possibility of resolving charges

short of further litigation if there were a short (three or four week) extension of the pretrial

motion deadline currently set for November 6, 2023. All agree to such an extension.

       2.      The requested extension is not for the purpose of delay, but to allow the parties to

continue attempts to resolve charges arising from this complex and wide-ranging case on terms

the parties assess to be in their interest, thereby avoiding potential miscarriage(s) of justice.

       WHEREFORE, Plaintiff requests that the Court:

       1.      Grant the motion and extend the pretrial motion deadline for approximately three

to four weeks from November 6, 2023 as to all Defendants who do not yet have a plea date;
    8:22-cr-00125-BCB-MDN Doc # 172 Filed: 11/06/23 Page 2 of 2 - Page ID # 438




        2.     Exclude the time between November 6, 2023 and the extended motions deadline,

pursuant to 18 U.S.C. § 3161(h)(7); and

        3.     In the alternative, if the Court determines it will deny the instant Motion, set the

matter for pretrial conference pursuant to Rule 17.1 before issuing a trial date, in order to

promote a fair and expeditious trial in light of the complexity and wide-ranging nature of this

case.

                                              UNITED STATES OF AMERICA, Plaintiff

                                              SUSAN LEHR
                                              Acting United States Attorney
                                              District of Nebraska


                                       By:    s/ John E. Higgins
                                              JOHN E. HIGGINS, #19546
                                              Assistant U.S. Attorney
                                              1620 Dodge Street, Suite 1400
                                              Omaha, NE 68102-1506
                                              Tel: (402) 661-3700
                                              Fax: (402) 345-5724
                                              E-mail: john.higgins@usdoj.gov



                                  CERTIFICATE OF SERVICE

        I hereby certify that on November 6, 2023, I electronically filed the foregoing with the
Clerk of the Court using the CM/ECF system which sent notification of such filing to all registered
participants.


                                                      s/ John E. Higgins
                                                      Assistant U.S. Attorney




*                                                 2

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