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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’ UNOPPOSED 

MOTION FOR EXTENSION OF TIME 

TO RESPOND TO UNITED STATES’ 

MOTION TO RESOLVE ATTORNEYCLIENT PRIVILEGE ISSUES 

“Defendant Not in Custody”

(Honorable Steven P. Logan)

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

moves for an 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 June 28, 2018. Defendant Brunst requests that the Court 

extend the response deadline as to all defendants by two weeks for a deadline of July 

13, 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 

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

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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 over the past six years. In 

addition to this motion, there are several outstanding motions that the defense is 

working on drafting or responding to. Additional time is needed to put together the

necessary information to submit a thorough response to the Government’s motion on 

privilege issues. The issues raised in the Government’s motion are of significant 

importance to how this case moves forward. The Government seeks a court order 

completely dissolving the attorney-client privilege as it relates to attorneys involved 

in Backpage litigation over the years. Given the importance of the issue at stake, 

Defendants submit that an additional two weeks is reasonable. 

Counsel for Defendant Brunst has conferred with Assistant United States 

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

an extension to July 13, 2018. Counsel for Mr. Brunst has conferred with counsel for 

the remaining defendants and they are in agreement with a two week extension of 

this deadline.

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 13, 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 28th day of June, 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 28th day of June, 2018, I electronically 

transmitted the foregoing 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

Case 2:18-cr-00422-DJH Document 203 Filed 06/28/18 Page 3 of 3