Unopposed Motion to Extend Time to File the Reply to the Response (ECF No. 63) to the Motion to Enter the Preliminary Order of Forfeiture (ECF No. 56) and Shorter's Response to Any Restitution Order

First Request

GEORGE FOLEY, Jr., District Judge.

The United States of America respectfully moves this Court for an Order extending the time for the United States to reply to the response (ECF No. 63) to the Motion to Enter the Preliminary Order of Forfeiture (ECF No. 56). This motion is the first request for an extension of time to reply to the response. The deadline to file the reply according to the ECF notice filed with the response is February 25, 2017, however according to LCR 12-1(a)(3), the deadline is March 1, 2017. The United States requests an extension of time up to, and including, March 15, 2017.

The grounds for extending the time are as follows.

Undersigned counsel contacted Raquel Lazo, counsel for Anthony Shorter, on February 27, 2017, and agreed to the extension of time.

In addition to the heavy caseload and work, undersigned counsel needs more time to compile and to write the government's arguments to Shorter's Response (ECF No. 63).

This Motion is not submitted solely for the purpose of delay or for any other improper purpose.

This Court should grant an extension of time up to, and including, March 15, 2017, for the United States to reply to the response (ECF No. 63) to the Motion to Enter the Preliminary Order of Forfeiture (ECF No. 56).