DOJ-OGR-00020604.jpg
574 KB
Extraction Summary
2
People
2
Organizations
3
Locations
3
Events
2
Relationships
1
Quotes
Document Information
Type:
Legal document
File Size:
574 KB
Summary
This legal document is a motion filed on January 12, 2023, by John M. Leventhal, attorney for the defendant-appellant, requesting a one-month extension to file an appellate brief, moving the deadline from January 30 to February 28, 2023. The justification for the extension is the difficulty in communicating with the client, who is incarcerated in Tallahassee, Florida, and the need for more time to complete the work. The motion notes that the opposing counsel, Assistant U.S. Attorney Andrew Rohrbach, does not object to the request.
People (2)
| Name | Role | Context |
|---|---|---|
| Andrew Rohrbach | Assistant United States Attorney |
Informed the appellant's attorney that the U.S. Attorney's Office does not object to the motion for a one-month exten...
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| JOHN M. LEVENTHAL, ESQ. (Ret.) | Attorney for Defendant-Appellant |
Signed and submitted the motion requesting an extension of time to file the appellant's brief.
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Organizations (2)
| Name | Type | Context |
|---|---|---|
| United States Attorney’s Office of the Southern District of New York | government agency |
Mentioned as the Respondent's office, which does not object to the requested extension.
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| AIDALA, BERTUNA & KAMINS, PC | company |
The law firm representing the Defendant-Appellant, for whom John M. Leventhal works.
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Timeline (3 events)
2023-01-12
Filing of a motion requesting a one-month extension of time to file the appellant's brief.
New York, New York
JOHN M. LEVENTHAL
Locations (3)
| Location | Context |
|---|---|
|
Location where the client is incarcerated.
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The jurisdiction of the Respondent United States Attorney's Office.
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Location where the document was dated and submitted from.
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Relationships (2)
The document states that Andrew Rohrbach, as opposing counsel, communicated to John M. Leventhal that his office does not object to the requested legal extension.
JOHN M. LEVENTHAL
→
attorney-client
→
Defendant-Appellant (client)
John M. Leventhal is identified as the 'Attorney for Defendant-Appellant' and refers to this individual as 'our client' throughout the document.
Key Quotes (1)
"[f]urther extensions of time will be disfavored."Source
— The Court
(A previous warning from the Court, which the attorney acknowledges while requesting the extension.)
DOJ-OGR-00020604.jpg
Quote #1
Full Extracted Text
Complete text extracted from the document (1,691 characters)
Case 22-1426, Document 40, 01/12/2023, 3451920, Page3 of 4
deadline of January 30, 2023, is the difficulty we have had communicating with our client who is incarcerated in Tallahassee, Florida, with limited phone access.
8. We have been working diligently on this case and have identified several issues that we believe merit appellate review. However, there is still considerable work to be done. We find that we need an additional month beyond the current deadline to complete this important work responsibly.
9. We believe that the above represents extraordinary circumstances that justify the relief sought. Denial of this application would cause irreparable harm to our client.
10. Assistant United States Attorney Andrew Rohrbach informed me today that Respondent United States Attorney’s Office of the Southern District of New York does not object to the Court granting our motion for an additional one-month extension of time to file Appellant’s brief.
11. We respectfully request that the Court extend our time to file our brief to February 28, 2023. We are cognizant that the Court warned that “[f]urther extensions of time will be disfavored.” For this reason, we request only the additional time that we believe is absolutely necessary in order to effectively represent our client.
WHEREFORE, it is respectfully requested that this Court issue an Order granting Appellant’s motion in its entirety, and for such other and further relief as this Court deems just and proper.
Dated: January 12, 2023
New York, New York
New York, New York
Respectfully Submitted,
AIDALA, BERTUNA & KAMINS, PC
By: [Signature]
JOHN M. LEVENTHAL, ESQ. (Ret.)
Attorney for Defendant-Appellant
JOHN M. LEVENTHAL, ESQ. (Ret.)
Attorney for Defendant-Appellant
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DOJ-OGR-00020604
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