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Michael D. Kimerer, #002492

Rhonda Elaine Neff, #029773

KIMERER & DERRICK, P.C.

1313 E. Osborn Road, Suite 100

Phoenix, AZ 85014

Telephone: 602-279-5900

Facsimile: 602-264-5566

mdk@kimerer.com

rneff@kimerer.com

Attorneys for Defendant, Jed Brunst 

UNITED STATES DISTRICT COURT

DISTRICT OF ARIZONA

United States of America,

 Plaintiff,

vs.

Michael Lacey, et. al.,

 Defendant.

Case No. 2:18-cr-00422-PHX-SPL (BSB)

DEFENDANTS’ SECOND 

UNOPPOSED MOTION FOR 

EXTENSION OF TIME TO RESPOND 

TO UNITED STATES’ MOTION TO 

RESOLVE ATTORNEY-CLIENT 

PRIVILEGE ISSUES 

“Defendant Not in Custody”

(Honorable Steven P. Logan)

Defendant John “Jed” Brunst, by and through undersigned counsel, hereby 

moves for a second extension of the deadline to respond to the United States’ 

pending Motion to Resolve Attorney-Client Privilege Issues filed on June 14, 2018 

(Doc. 195). The current deadline is July 13, 2018. Defendant Brunst requests that the 

Court extend the response deadline as to all defendants by one additional week for a 

deadline of July 20, 2018. As grounds in support of this Motion, Defendant states as 

follows:

This case involves a 93-count indictment alleging a range of criminal acts 

involving Conspiracy, Concealment, Money Laundering (transactional and 

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international promotional), and Travel Act - Facilitate Prostitution. This case 

involves complex legal issues that have been being litigated for several years. The 

Government’s motion seeks to resolve attorney-client privilege issues that are deeply 

rooted in the past litigation involving these defendants. The Government’s motion 

seeks to do away with the highly protected attorney-client privilege. The ruling on 

this motion has a number of possible consequences to the defendants in this case. 

Defendants originally sought a two week extension of the deadline believing a 

response could be completed during that time. However, the complexity of the issues 

and the need for a large number of attorneys to be involved in the drafting of the 

response requires additional time. The defendants believe that one additional week 

will be sufficient time to prepare a response to the Motion. 

Counsel for Mr. Brunst has conferred with the counsel for the remaining 

defendants and they are in agreement with a one week extension of this deadline. 

Counsel for Mr. Brunst has also conferred with the assigned Assistant United States 

Attorney, Kevin Rapp, regarding this additional extension and he has no objection to 

an extension to and including July 20, 2018. 

The defense does not expect that this motion will result in an excludable delay 

under 18 U.S.C. § 3161(h). 

Therefore, Defendant Brunst hereby respectfully requests this Court extend 

the deadline for filing a response to the United States’ Motion to Resolve AttorneyClient Privilege Issues (Doc. 195) to July 20, 2018. Defendant Brunst is seeking to 

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extend this deadline as to all defendants. A proposed order is attached for the Court’s 

consideration. 

Respectfully submitted this 11th day of July, 2018.

KIMERER & DERRICK, P.C.

/s/Michael D. Kimerer

Michael D. Kimerer

Rhonda Elaine Neff

Attorneys for Defendant John “Jed” Brunst

CERTIFICATE OF SERVICE

I hereby certify that on this 11th day of July, 2018, I electronically 

transmitted the foregoing Second Unopposed Motion for Extension of Time to File 

Response to United States’ Motion to Resolve Attorney-Client Privilege Issues to 

the Clerk of the Court by filing with the CM/ECF system and understand a copy of 

the filing will be emailed to the attorneys of record.

By: /s/ Melissa Wallingsford

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