1UNITED STATES DISTRICT COURTFOR THE DISTRICT OF NEW HAMPSHIRE ____________________________________ UNITED STATES OF AMERICA))v.)Criminal No.1:07-CR-189-2-GZS)JASON GERHARD) ____________________________________)
DEFENDANT JASON GERHARD’SPARTIALLY ASSENTED MOTION FOR LEAVE TO FILE LATE
The Defendant, JASON GERHARD, through his undersigned counsel, respectfully movesthis Honorable Court, for leave to file late his Exhibit List with respect to the above captionedmatter. 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 defendantwho 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 tocounsel for Cirino Gonzalez.3. Upon information and belief Assistant U.S. Attorney Arnold Huftalen assents to thegranting 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 arecontained herein.Respectfully Submitted,Attorneys for the Defendant,/s/ Stanley W. NorkunasStanley W. Norkunas
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