DOJ-OGR-00020613.jpg

606 KB

Extraction Summary

4
People
2
Organizations
1
Locations
3
Events
4
Relationships
0
Quotes

Document Information

Type: Legal document
File Size: 606 KB
Summary

This legal document, dated February 14, 2023, is a motion requesting permission from the Court to file an oversized appellate brief of up to 35,000 words, an increase from a previously approved 20,000 words. The filer argues the extra length is necessary to adequately address five complex legal issues, including statute of limitations and juror misconduct. The document confirms that the opposing counsel, Assistant U.S. Attorneys from the Southern District of New York, have been notified of this request via email.

People (4)

Name Role Context
Andrew Rohrbach Assistant United States Attorney
Recipient of an email notification regarding the motion to file an oversized brief.
Lara Pomerantz Assistant United States Attorney
Recipient of an email notification regarding the motion to file an oversized brief.
Alison Moe Assistant United States Attorney
Recipient of an email notification regarding the motion to file an oversized brief.
Maureen Comey Assistant United States Attorney
Recipient of an email notification regarding the motion to file an oversized brief.

Organizations (2)

Name Type Context
The Court government agency
The judicial body that granted previous motions and is being requested to permit the filing of an oversized brief.
Appellee United States Attorney's Office for the Southern District of New York government agency
The opposing party in the legal case, which was notified of the motion.

Timeline (3 events)

2023-01-17
The Court granted the filer's motion for an enlargement of time to file the Appellant's brief.
The Court Appellant's counsel
2023-01-18
The Court granted the filer's request to file a brief of no more than 20,000 words.
The Court Appellant's counsel
2023-02-14
A motion was filed requesting permission to file a brief of no more than 35,000 words.
Appellant's counsel

Locations (1)

Location Context
The jurisdiction of the United States Attorney's Office involved in the case.

Relationships (4)

Appellant's counsel (filer) professional Andrew Rohrbach
The document shows they are opposing counsel in a legal case (Case 22-1426), with the filer notifying Rohrbach of a legal motion.
Appellant's counsel (filer) professional Lara Pomerantz
The document shows they are opposing counsel in a legal case (Case 22-1426), with the filer notifying Pomerantz of a legal motion.
Appellant's counsel (filer) professional Alison Moe
The document shows they are opposing counsel in a legal case (Case 22-1426), with the filer notifying Moe of a legal motion.
Appellant's counsel (filer) professional Maureen Comey
The document shows they are opposing counsel in a legal case (Case 22-1426), with the filer notifying Comey of a legal motion.

Full Extracted Text

Complete text extracted from the document (1,829 characters)

Case 22-1426, Document 50, 02/14/2023, 3469305, Page2 of 4
motion to file an oversized brief in which we estimated that we would need permission to file a brief of no more than 20,000 words to fully brief the issues for appeal.
7. On January 17, 2023, the Court granted our motion for an enlargement of time to file Appellant's brief.
8. On January 18, 2023, the Court granted our request to file a brief of no more than 20,000 words.
9. We have completed a draft of our brief and are now in a more definite position to request from the Court an additional 15,000 words so that we be permitted to file a brief of no more than 35,000 words.
10. Our brief contains five points. These points raise issues pertaining to statute of limitations; a non-prosecution agreement; juror misconduct and a post-verdict hearing; and sentence. Some of these issues involve detailed analysis of case law, statutory interpretation and legislative history, while others involve an explication of the evidence and procedural posture relevant to the issues raised. In an effort to shorten our brief, we have already omitted what was a lengthy summary of the evidence at trial in favor of marshalling only the evidence essential to an analysis of the issues being raised.
11. We have notified Appellee United States Attorney's Office for the Southern District of New York today, by email to Assistant United States Attorneys Andrew Rohrbach, Lara Pomerantz, Alison Moe, and Maureen Comey, that we are making this motion and have asked their position and if they intend to file a response. We have not received a reply as of the time of filing.
12. For the reasons stated, we respectfully request that the Court permit us to file a principal brief of no more than 35,000 words and would consent to Appellee filing a brief of
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DOJ-OGR-00020613

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