MOTION FOR EXTENSION OF TIME TO FILE RESPONSE

(First Request)

CAM FERENBACH, Magistrate Judge.

COMES NOW the United States of America, by and through DANIEL G. BOGDEN, the undersigned Assistant United States Attorney, Kimberly M. Frayn, and hereby respectfully move the Court for an extension of time to file the Government's response to defendant Wright's motion to dismiss Counts One through Four of the Indictment (Doc. No. 154), to a date and time convenient to the Court, but not less than fourteen days after the current date upon which the Government must file it's response, that is, fourteen days after November 30, 2015, which is approximately December 14, 2015, for the following reasons:

On November 13, 2015, Defendant Wright filed a motion to dismiss Counts One through Four of the Indictment (Doc. No. 154). The Government's time to file its response to the motion to dismiss Counts One through Four of the Indictment is presently set for Monday, November 30, 2015. However, Government counsel will be out of the office and out of the state on a previously scheduled trip on November 23, 2015, which is expected to approximately ten days to last two weeks. Althought it is anticipated that Defendant Wright will oppose the brief fourteen day extension of time, Government respectfully moves the Court for an extension of time to file the Government's response to defendant Wright's motion (Doc. No. 154), to a date and time convenient to the Court, but not before December 14, 2015, which is approximately fourteen days after the date upon which the Government's response is presently due.

Although defendant Wright is in custody, the brief requested delay will not unduly prejudice him and is not made merely for purposes of delay, but to allow the Govenrment continuity of counsel. Granting of this request will not affect the trial in this matter, which is presently set for February 22, 2016.

This is the first request to extend time for the Government to file its response.

THEREFORE, the United States respectfully requests the Court to extend the Govenrment's time to file its response to defendant Wright's dismiss Counts One through Four of the Indictment (Doc. No. 154), to a date and time convenient to the Court, but not less than fourteen days after the current date upon which the Government must file it's response, that is, December 14, 2015.

ORDER

After considering Government's motion to extend the Govenrment's time to file its response to defendant Wright's motion to dismiss Counts One through Four of the Indictment (Doc. No. 154), to a date and time convenient to the Court, but not less than fourteen days after the current date upon which the Government must file it's response, that is, fourteen days after November 30, 2015, which is approximately December 14, 2015, the Court hereby finds good cause to grant the Government's request.

THEREFORE, IT IS HEREBY ORDERED that the Government's Motion For Extention Of Tme to File Response is GRANTED and the Government shall file its response before midnight on Monday, December 14, 2015.