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PICCARRETA DAVIS KEENAN FIDEL PC

2 East Congress Street, Suite 1000

Tucson, Arizona 85701-1782

(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

DISTRICT OF ARIZONA

United States of America,

 Plaintiff,

v.

6. Andrew Padilla,

 (Counts 1-51)

 Defendant.

NO. CR-18-00422-06-PHX-SPL

UNOPPOSED MOTION FOR EXTENSION 

OF TIME TO REPLY TO RESPONSE 

(DOC. 476) TO MOTION TO DISMISS 

DUE TO GOVERNMENT 

INTERFERENCE WITH RIGHT TO 

COUNSEL AND REQUEST FOR 

DISCLOSURE OR, IN THE 

ALTERNATIVE, MOTION TO 

WITHDRAW (DOC. 456)

(First Request)

Defendant Andrew Padilla, by and through undersigned counsel, pursuant to LRCrim 

12.1(b) and LRCiv 7.3, respectfully moves for an extension of time to file his Reply to the 

Government’s Response (Doc. 476) to his Motion to Dismiss due to Government 

Interference with Right to Counsel and Request for Disclosure or, in the Alternative, Motion 

to Withdraw (Doc. 456). The government’s response raises many factual and legal matters 

that were beyond the scope of Mr. Padilla’s motion, and Mr. Padilla respectfully requests 

that the current due date for this reply, March 4, 2019, be extended for four days to March 8, 

Case 2:18-cr-00422-DJH Document 480 Filed 02/28/19 Page 1 of 3
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2019. Undersigned counsel has contacted counsel for the government, Assistant United 

States Attorney Kevin Rapp, who does not oppose this request. Undersigned counsel has 

contacted counsel for all co-defendants who also agree to the request for an extension of 

time.

For the foregoing reasons, Mr. Padilla respectfully requests this Court to issue its 

order extending the time for filing his Reply to the Government’s Response to his Motion to 

Dismiss due to Government Interference with Right to Counsel and Request for Disclosure 

or, in the Alternative, Motion to Withdraw, to March 8, 2019.

RESPECTFULLY SUBMITTED this 28th day of February, 2019.

PICCARRETA DAVIS KEENAN FIDEL PC

By: /s/ Michael L. Piccarreta

Michael L. Piccarreta

Attorney for Defendant Andrew Padilla

Case 2:18-cr-00422-DJH Document 480 Filed 02/28/19 Page 2 of 3
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CERTIFICATE OF SERVICE

I hereby certify that on the 28th day of February, 2019, I electronically 

transmitted the foregoing to the Clerk of the Court via the CM/ECF system for filing 

and transmittal of a Notice of Electronic Filing to the following CM/ECF registrants:

Reginald Jones: Reginald.Jones@usdoj.gov

Peter S. Kozinets: Peter.Kozinets@usdoj.gov

John Kucera: John.Kucera@usdoj.gov

Margaret Perlmeter: Margaret.Perlmeter@usdoj.gov

Kevin Rapp: Kevin.Rapp@usdoj.gov

Andrew Stone: Andrew.Stone@usdoj.gov

Thomas Bienert: tbienert@bmkattorneys.com

Paul Cambria: pcambira@lglaw.com

Robert Corn-Revere: bobcornrevere@dwt.com

Bruce Feder: bfeder@federlaw.com

James Grant: jimgrant@dwt.com

Michael D. Kimerer, mdk@kimerer.com

Gary Lincenberg: glincenberg@birdmarella.com

Case 2:18-cr-00422-DJH Document 480 Filed 02/28/19 Page 3 of 3