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Robert Corn-Revere (D.C. Bar No. 375415, admitted pro hac vice) 

DAVIS WRIGHT TREMAINE LLP 

1919 Pennsylvania Avenue NW, Suite 800 

Washington, DC 20006-3401 

Telephone: (202) 973-4225 

Facsimile: (202) 973-4499 

Email: robertcornrevere@dwt.com 

James C. Grant (Wash. Bar No. 14358, admitted pro hac vice) 

DAVIS WRIGHT TREMAINE LLP 

920 Fifth Ave, Suite 3300 

Seattle, WA 98104-1610 

Telephone: (206) 757-8096 

Facsimile: (206) 757-7096 

Email: jamesgrant@dwt.com 

Counsel for Michael Lacey and James Larkin 

IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF ARIZONA 

United States of America, 

Plaintiff, 

v. 

Michael Lacey, et al., 

Defendants. 

No. CR-18-422-PHX-SMB 

UNOPPOSED MOTION TO 

EXTEND DEADLINE FOR REPLY 

TO RESPONSE TO DEFENDANTS’ 

MOTION TO DISMISS INDICTMENT 

Case 2:18-cr-00422-DJH Document 642 Filed 06/19/19 Page 1 of 4
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Defendants Michael Lacey, James Larkin, John Brunst and Scott Spear, by and 

through their undersigned attorneys, respectfully move the Court to extend the deadline for replying to the Government’s Response to Motion to Dismiss Indictment for 

two-weeks, until July 3, 2019. On May 3, 2019, Defendants Michael Lacy, James 

Larkin, John Brunst, and Scott Spear filed a Motion to Dismiss Indictment (Doc. 561). 

The Government moved to extend the time to respond to the Motion to Dismiss until 

June 12, 2019, which request was granted. (Doc. 618) The reason for the government’s request was the anticipated filing of amicus briefs supporting Defendants. In 

its unopposed request, the government indicated it would not oppose a corresponding 

extension for Defendants’ reply. (Doc. 612). 

Defendants hereby request a two-week extension of time, and the government 

has indicated it is not opposed to this motion. In the past week, however, Defendants 

have been advised counsel for Equality Now and Legal Momentum have expressed 

an intention to file an amicus brief supporting the government, and counsel for those 

groups have entered appearances in the case. Defendants have not been advised of 

when that filing might take place. When that amicus brief is filed, it may be necessary 

for Defendants to seek a further adjustment of the reply deadline, and possible of the 

page limit, and will confer with parties at that time. 

Therefore, Defendants request that the Court extend the time for their reply to 

the response to the Motion to Dismiss indictment until July 3, 2019. 

DATED this 19th day of June, 2019. 

DAVIS WRIGHT TREMAINE LLP 

s/ James C. Grant

s/ Robert L. Corn-Revere 

Attorneys for Michael Lacey and James Larkin 

Case 2:18-cr-00422-DJH Document 642 Filed 06/19/19 Page 2 of 4
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Pursuant to the District’s Electronic Case Filing Administrative Policies and 

Procedures Manual (May 2018) § II(C)(3), James C. Grant hereby attests that 

all other signatories listed, and on whose behalf this filing is submitted, concur 

in the filing’s content and have authorized its filing. 

s/ Paul J. Cambria, Jr. 

LIPSITZ GREEN SCIME CAMBRIA LLP 

Attorneys for Michael Lacey 

s/ Thomas H. Bienert, Jr. 

BIENERT KATZMAN, PLC 

Attorneys for James Larkin 

s/ Ariel A. Neuman 

BIRD MARELLA BOXER WOLPERT NESSIM 

DROOKS LINCENBERG AND RHOW 

Attorneys for John Brunst 

s/ Bruce Feder 

FEDER LAW OFFICE PA 

Attorney for Scott Spear 

Case 2:18-cr-00422-DJH Document 642 Filed 06/19/19 Page 3 of 4
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CERTIFICATE OF SERVICE 

I hereby certify that on June 19, 2019, a true and correct copy of the foregoing 

document was electronically filed with the Clerk of the United States District Court of 

the District of Arizona by using the CM/ECF system, and that service will be 

accomplished by the CM/ECF system to all counsel of record. 

s/ James C. Grant 

Attorney for Michael Lacey and James Larkin 

Case 2:18-cr-00422-DJH Document 642 Filed 06/19/19 Page 4 of 4