UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF NEW HAMPSHIRE

____________________________________
UNITED STATES OF AMERICA )
)
v. ) Criminal No.1:07-CR-189-2-GZS
)
JASON GERHARD )
____________________________________)

DEFENDANT JASON GERHARD’S

PARTIALLY ASSENTED MOTION FOR LEAVE TO FILE LATE
The Defendant, JASON GERHARD, through his undersigned counsel, respectfully moves
this Honorable Court, for leave to file late his Exhibit List with respect to the above captioned

matter. Counsel requests he be able to file same on March 17, 2008.

1. Counsel for the defendant needs additional time in order to consult with the defendant

who is in custody to finalize the exhibit list.

2. A draft of the defendant’s Exhibit list has been served to counsel for the USA and to

counsel for Cirino Gonzalez.

3. Upon information and belief Assistant U.S. Attorney Arnold Huftalen assents to the

granting of this request.

4. Attorney David H. Bownes, counsel for Cirino Gonzalez assents to this request.

5. Undersigned counsel has been unable to contact co-defendant Daniel Riley.

6. Wherefore, the defendant requests that this Court grant such relief requested herein.

7. No supporting memorandum accompanies this motion because the authorities are

contained herein.

Respectfully Submitted,
Attorneys for the Defendant,

/s/ Stanley W. Norkunas

Stanley W. Norkunas

1
 11 Kearney Square
Lowell, MA 01852
978 454-7465

/s/ Liam D. Scully

Liam D. Scully
228 Central Street
Lowell, MA 01852
978 458-0000

Dated: 3/13/08