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PICCARRETA DAVIS KEENAN FIDEL PC

2 East Congress Street, Suite 1000

Tucson, AZ 85701

(520) 622-6900

Michael L. Piccarreta

State Bar No. 003962

Email: mlp@pd-law.com

Attorney for Defendant Andrew Padilla

IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF ARIZONA

United States of America,

 Plaintiff,

vs.

6. Andrew Padilla,

 (Counts 1-51)

 

 Defendant.

NO. CR-18-00422-06-PHX-SPL (BSB)

UNOPPOSED MOTION FOR 

EXTENSION OF TIME TO FILE REPLY 

TO RESPONSE TO MOTION FOR 

ITEMIZATION OF BRADY/GIGLIO

MATERIAL (DOCS. 273, 294)

“Defendant Not In Custody”

(FIRST REQUEST)

Defendant Andrew Padilla, by and through his undersigned attorney, hereby moves for 

an extension of the deadline to file his reply to the government’s response (Doc. 294) to his 

motion for itemization of Brady/GiglioMaterial (Doc. 273). The current deadline is September 

11, 2018. Defendant Padilla requests that the Court extend the reply deadline for one week for 

a revised deadline of September 18, 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, Travel Act violations premised upon underlying state law prostitution offenses, 

conspiracy to commit money laundering, and money laundering. The case involves complex 

and novel legal issues, voluminous discovery, and massive seizures of defendants’ assets. 

Case 2:18-cr-00422-DJH Document 297 Filed 09/06/18 Page 1 of 3
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There are several outstanding motions relating to several of these issues and additional time is 

necessary for the preparation of a thorough reply to the government’s response to Mr. Padilla’s 

motion for itemization of Brady/Giglio material. Under these circumstances, Mr. Padilla 

submits that an extension of one week to file his reply is reasonable.

Counsel for Mr. Padilla has conferred with Assistant United States Attorney Kevin 

Rapp regarding the need for this extension and he has no objection to an extension to 

September 18, 2018. Counsel for Mr. Padilla has conferred with counsel for the remaining 

defendants and they are in agreement with a one-week extension of the current deadline.

The defense does not expect that this motion will result in excludable delay under 18 

U.S.C. § 3161(h)(1)(D).

Therefore, Mr. Padilla hereby respectfully requests this Court to extend the deadline 

for filing his reply to the government’s response to his motion for itemization of Brady/Giglio

material to September 18, 2018. A proposed order is attached for the Court’s consideration.

RESPECTFULLY SUBMITTED this 6th day of September, 2018.

PICCARRETA DAVIS KEENAN FIDEL PC

By: /s/ Michael L. Piccarreta

Michael L. Piccarreta

Attorney for Andrew Padilla

Case 2:18-cr-00422-DJH Document 297 Filed 09/06/18 Page 2 of 3
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On September 6, 2018, a PDF version

of this document was filed with the

Clerk of Court using the CM/ECF

System for filing and for Transmittal

of a Notice of Electronic Filing to the

following CM/ECF registrants:

Reginald Jones, reginald.jones4@usdoj.gov

Peter Kozinets, peter.kozinets@usdoj.gov

Margaret Perlmeter, margaret.perlmeter@usdoj.gov

Kevin Rapp, kevin.rapp@usdoj.gov

Andrew Stone, andrew.stone@usdoj.gov

Paul Cambria, pcambria@lglaw.com

Tom Bienert, tbienert@bmkattorneys.com

Bruce Feder, bf@federlawpa.com

Michael Kimerer, mdk@kimerer.com

Stephen Weiss, sweiss@karpweiss.com

Case 2:18-cr-00422-DJH Document 297 Filed 09/06/18 Page 3 of 3