Case: 12-1236

Document: 00116387759

Page: 1

Date Filed: 06/05/2012

Entry ID: 5646676

UNITED STATES COURT OF APPEALS FOR THE FIRST CIRCUIT Appeal No. 12-1236 IN RE: REQUEST FROM THE UNITED KINGDOM PURSUANT TO THE TREATY BETWEEN THE GOVERNMENT OF THE UNITED STATES OF AMERICA AND THE GOVERNMENT OF THE UNITED KINGDOM ON MUTUAL ASSISTANCE IN CRIMINAL MATTERS IN THE MATTER OF DOLOURS PRICE UNITED STATES OF AMERICA, Petitioner-Appellee v. TRUSTEES OF BOSTON COLLEGE, ET AL., Movants-Appellants GOVERNMENT’S MOTION FOR ORDER EXTENDING THE TIME – TO JULY 6, 2012 – WITHIN WHICH IT MUST FILE ITS RESPONSIVE BRIEF The government respectfully moves this Court to enter an order extending the due date for the government’s responsive brief by 31 days, to July 6, 2012. In support of this motion, the government states the following: 1. This is Boston College’s appeal from orders entered by the district court

in connection with subpoenas issued by the United States pursuant to a Mutual Legal Assistance Treaty between the United States and the United Kingdom. 2. Boston College filed its brief on May 4, 2012, and the government’s

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Case: 12-1236

Document: 00116387759

Page: 2

Date Filed: 06/05/2012

Entry ID: 5646676

brief is currently due on June 7, 2012. The government has not previously requested an extension of its deadline. 3. This appeal raises potentially important questions regarding the district

court’s application of the relevant legal standards in determining, through an in camera review process, the documents within Boston College’s custody and control responsive to the United Kingdom’s request. 4. The undersigned is currently involved in drafting the government’s

responsive brief in the consolidated appeals United States v. Jones, 10-2495, and United States v. Tavares, 10-1781, 11-1055, in which the defendants present a number of challenges their convictions and sentences, after a 10-day trial, on charges relating to child prostitution. The government’s brief is currently due on June 8, 2012. Prior to that, the undersigned was involved in writing or reviewing briefs in a number of other appeals, including, most recently, United States v. Massaro, No. 11-2067 (government’s brief filed May 16, 2012), United States v. Sasso, No. 111094 (government’s brief filed May 18, 2012), and United States v. Gomez, No. 111943 (government’s brief filed May 21, 2012). As a result, the undersigned has not been able to begin work on the government’s response in this case. 5. Given the nature of the issues raised, the government’s responsive brief

will need to be circulated for review to a number of governmental entities beyond the
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Case: 12-1236

Document: 00116387759

Page: 3

Date Filed: 06/05/2012

Entry ID: 5646676

U.S. Attorney’s Office and sufficient time is needed to incorporate any comments that are received. Respectfully submitted, CARMEN M. ORTIZ United States Attorney By: /s/Randall E. Kromm RANDALL E. KROMM Assistant U.S. Attorney

Certificate of Service I, Randall E. Kromm, AUSA, hereby certify that on June 5, 2012, I electronically served a copy of the foregoing document on the following registered participants of the CM/ECF system: Jeffrey Swope, Esq. Edwards Wildman Palmer LLP 111 Huntington Ave. Boston, MA 02199 /s/Randall E. Kromm RANDALL E. KROMM Assistant U.S. Attorney

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