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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

Kevin M. Rapp (AZ 14249)

Assistant U.S. Attorney

40 N. Central Avenue, Suite 1800

Phoenix, Arizona 85004-4408

Telephone: (602) 514-7500

kevin.rapp@usdoj.gov

Attorneys for Plaintiff

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)

JOINT MOTION FOR 

EXTENSIONS OF TIME 

“Defendant Not in Custody”

(Honorable Steven P. Logan)

Defendant Michael Lacey, by and through his undersigned counsel, hereby submits the 

instant joint motion for an extension of certain deadlines for Defendant and the government. 

Presently, Defendant’s deadline for submission of a reply brief on Defendant’s Motion for 

Disclosure (Doc. 202)is August 9, 2018. The government’s deadline for submission of a reply 

brief on the Government’s Motion to Resolve Privilege Issues (Doc. 195) is August 10, 2018. 

Case 2:18-cr-00422-DJH Document 260 Filed 08/09/18 Page 1 of 4
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Counsel for the parties discussed their current deadlines and their respective needsfor extensions 

of those deadlines, thereby agreeing to jointly move for an extension of their respective 

deadlines. As grounds in support of this Motion, the parties state as follows:

This case originally involved a 93-count indictment and was designated complex. 

The parties have engaged in motion practice, including the filing of Defendant’s Motion 

for Disclosure (Doc. 202) and the Government’s Motion to Resolve Privilege Issues (Doc. 

195). 

On July 17, 2018, this Court granted Defendant’s Unopposed Motion for an 

Extension of the deadline to submit a reply brief on Defendant’s Motion for Disclosure and 

set the deadline for August 9, 2018 for Defendant and each of the Co-Defendant’s who had 

joined in the motion. (Doc. 222.) On July 25, 2018, this Court granted the Government’s 

Unopposed Motion for an Extension of the deadline to submit a reply brief on the 

Government’s Motion to Resolve Privilege Issues and set the deadline for August 10, 2018. 

(Doc. 233.) 

Since this Court set those deadlines, a grand jury sitting in this District issued a 100-

count superseding indictment. (See Doc. 230.) In light of the new charges, the need for 

counsel to travel for the arraignment, and other pressing matters, the parties would greatly 

benefit from a one-week extension of their respective deadlines. The parties respectfully 

request that this Court extend the deadline for Defendant’s reply brief on Defendant’s 

Motion for Disclosure from August 9, 2018 to August 16, 2018 for Defendant and all CoDefendants who have joined in the motion, and respectfully request that this Court extend 

the government’s deadline for submission of the reply brief on the Government’s Motion 

to Resolve Privilege Issues from August 10, 2018 to August 17, 2018. 

The parties do not expect that this motion will result in any excludable delay under 

18 U.S.C. § 3161(h).

A proposed order is attached for the Court’s consideration. 

Case 2:18-cr-00422-DJH Document 260 Filed 08/09/18 Page 2 of 4
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Respectfully submitted this 9th day of August, 2018, 

/s/ Erin E. McCampbell

Erin E. McCampbell, Esq. 

LIPSITZ GREEN SCIME CAMBRIA LLP

Attorneys for Defendant Michael Lacey

/s/ Kevin M. Rapp

Kevin M. Rapp, Esq.

ASSISTANT UNITED STATES ATTORNEY

Attorneys for Plaintiff

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CERTIFICATE OF SERVICE

I hereby certify that on this 9th day of August 2018, I electronically transmitted the 

foregoing Joint Motion for Extensions of Time 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 260 Filed 08/09/18 Page 4 of 4