walker

UNITED STATES COURT OF APPEALS

FOR THE DISTRICT OF COLUMBIA CIRCUIT

UNITED STATES OF AMERICA )

                                        Appellee, )

                                                    v. ) CASE NUMBER:

                    TYRONE xxxxxx, )

                                   Appellant. )

UNOPPOSED MOTION FOR EXTENSION OF TIME
WITHIN WHICH TO FILE APPELLANT'S REPLY BRIEF

Appellant respectfully moves this Court, pursuant to Circuit Rule 27(h)(1), for a 5 day extension of time, to June 16, 1996, within which to file his Reply brief. Appellant's brief is presently due on June 11, 1996. Although oral argument has been scheduled, it has not been set until October of 1996, and the government has no opposition to this motion being granted. As further grounds for this motion, appellant states the following:

1. Undersigned counsel has an initial brief due on June 11, 1996, in United States v. Tavares, Case No. 93-9035. Undersigned counsel inherited this appeal from Sandra Roland, who was forced to take extended leave.

2. In addition, undersigned counsel has been attending to numerous other responsibilities in serious felony cases pending in District Court, responsibilities which are made more pressing by the fact that counsel will be out of the jurisdiction for three weeks beginning on June 17th.

3. In light of these circumstances, undersigned counsel requires an additional five days to complete the preparation of the Reply brief.

4. Pursuant to Circuit Rule 27(h)(2), appellant's counsel contacted Anjali Chaturvedi, in the Appellate Division, United States Attorney's Office, counsel for appellee, United States of America, who indicated she does not oppose this request.

5. We make this motion in good faith, for reasons of compelling necessity, and not for purposes of delay.

WHEREFORE, appellant respectfully requests that his motion for an extension of time to file his Reply brief until June 16, 1996, be granted.

Respectfully submitted,

A.J. KRAMER

FEDERAL PUBLIC DEFENDER

L. Barrett Boss

Assistant Federal Public Defender

625 Indiana Ave., N.W., Suite 550

Washington, D.C. 20001

(202) 208-7500

CERTIFICATE OF SERVICE

I hereby certify that a true and accurate copy of the foregoing motion was served upon Anjali Chaturvedi, Esquire, Appellate Division, office of the United States Attorney by hand delivering a copy to a receptacle at the United States District Courthouse, 3rd and Constitution Avenue, N.W., Washington, D.C. provided for pleadings upon the Office of the United States Attorney, on this 3rd day of June, 1996.

L. Barrett Boss

Assistant Federal Public Defender