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Erin E. McCampbell (NY 4480166, admitted pro hac vice)

LIPSITZ GREEN SCIME CAMBRIA LLP

42 Delaware Avenue, Suite 120

Buffalo, New York 14202

Telephone: (716) 849-1333

Facsimile: (716) 855-1580

emccampbell@lglaw.com

Attorneys for Defendant Michael Lacey

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF ARIZONA

United States of America,

 Plaintiff,

vs.

Michael Lacey, et al., 

 

 Defendants.

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

DEFENDANT’S UNOPPOSED MOTION 

FOR EXTENSION OF TIME TO SUBMIT 

REPLY ON DEFENDANT’S MOTION 

FOR DISCLOSURE (DOC. 202)

“Defendant Not in Custody”

(Honorable Steven P. Logan)

Defendant Michael Lacey, by and through his undersigned attorney, hereby moves for 

an extension of the deadline to submit the reply on Defendant’s Motion for Disclosure (Doc.

202). The current deadline is July 19, 2018. Defendant Lacey requests that the Court extend the 

response deadline by three weeks for a revised deadline of August 9, 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 involves complex legal 

issues that have been being litigated for several years. In addition to this motion, there are 

several outstanding motions that the defense is working on drafting or responding to. 

Case 2:18-cr-00422-DJH Document 221 Filed 07/17/18 Page 1 of 2
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Additional time is needed to put together the necessary information to submit a thorough 

reply to the Government’s opposition to Defendant Lacey’s Motion for Disclosure. 

Moreover, additional time is needed to accommodate counsel’s appearances on other cases 

and counsel’s previously scheduled vacation. In light of the foregoing, Defendant submits

that an additional three weeks is reasonable.

Counsel for Defendant Lacey has conferred with Assistant United States Attorney 

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

to August 9, 2018. Counsel for Mr. Lacey has conferred with counsel for the remaining 

defendants and they are in agreement with a three 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 Lacey hereby respectfully requests this Court extend the 

deadline for filing a reply on Defendant’s Motion for Disclosure to August 9, 2018. This

extension is sought on behalf of Defendant Lacey’s Co-Defendants, all of whom have joined in 

Defendant Lacey’s Motion for Disclosure. A proposed order is attached for the Court’s 

consideration. 

Respectfully submitted this 17th day of July, 2018, 

/s/ Erin E. McCampbell

Erin E. McCampbell, Esq. 

LIPSITZ GREEN SCIME CAMBRIA LLP

Attorneys for Defendant Michael Lacey

CERTIFICATE OF SERVICE

I hereby certify that on this 17th date of July 2018, I electronically transmitted the foregoing 

Unopposed Motion for Extension of Time to File a Reply on Defendant’s Motion for Disclosure 

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/ April Kelly

Case 2:18-cr-00422-DJH Document 221 Filed 07/17/18 Page 2 of 2