IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF COLORADO

Criminal Action No. 11-cr-00355-MSK-02 

UNITED STATES OF AMERICA, 

 Plaintiff, 

v. 

1. WAUNITA WEINGART, 

2. JOHN PHILLIP GALLEGOS, 

3. ALOIS CRAIG WEINGART. 

 Defendants. 

DEFENDANT JOHN GALLEGOS’ UNOPPOSED MOTION FOR ADDITIONAL TWO 

WEEKS IN WHICH TO FILE MOTIONS 

 Defendant John Gallegos, by and through undersigned counsel, hereby requests that this Court 

enter an Order permitting an additional two weeks in which to file motions. As grounds, Mr. Gallegos 

states as follows: 

1. Currently, any defense motions in the above-captioned case are due to be filed today, Monday, 

March 12, 2012. 

2. Defense counsel continues to work diligently on this case. However, a short extension of time is 

needed for counsel to file motions.1

3. In compliance with this Court’s procedures, counsel recognizes that a showing of good cause is 

required for motions for extensions of time. Here, such good cause exists. Undersigned counsel 

has spent and continues to spend substantial time reviewing the 28,000-plus pages of discovery 

provided to date. Further, with the unique circumstances in this case, counsel has been diligently 

engaging in conversations with the U.S. Attorney’s Office to determine which path this case will 

take. Undersigned counsel hopes that these discussions will result, in the next two weeks, in an 

agreed-upon resolution of the case. Finally, counsel has been working with an expert witness, 

 

1

 At this time, counsel for Mr. Gallegos only anticipates filing a Motion for Severance and a Motion for a James Proffer, 

unless the case is resolved without trial by agreement of the Parties. 

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whose opinion will be crucial to this case. Additional time is necessary for the expert to 

conclude his work, as is court permission for him to review certain materials in this case. 

Undersigned counsel is filing today an ex parte motion to facilitate his work. 

4. Defense counsel is only requesting an additional two weeks, making a new filing deadline for 

Mr. Gallegos’ motions of Monday, March 26, 2012. 

5. New counsel was just appointed by this Court today, March 12, 2012, for Mr. Gallegos’ codefendant, Ms. Waunita Weingart. As expected, Ms Weingart’s new Counsel has filed an 

Unopposed Motion to Extend Motion Filing Deadline today. Doc. No. 68 Undersigned counsel 

therefore believe that a brief enlargement of time of two weeks for Mr. Gallegos to file his 

motions will not prejudice other defendants, the Court, or require a continuance of the trial now 

set for September 2012. 

6. Undersigned counsel has spoken with the assigned prosecutor, Ms. Linda Kaufman, who stated 

that she does not oppose this limited extension for the filing deadline. Mr. Gallegos will not 

object to a commensurate extension of time for the Government to respond to his motions. 

WHEREFORE, Mr. Gallegos respectfully requests that this Court grant his Motion for Additional 

Time in which to File Motions, specifically allowing for an additional two weeks in which to file 

motions. 

Respectfully submitted this 12th day of March, 2012. 

 

 s/William Taylor 

William L. Taylor 

RIDLEY, MCGREEVY & WINOCUR, P.C. 

Attorney for John Gallegos 

Case No. 1:11-cr-00355-MSK Document 70 filed 03/12/12 USDC Colorado pg 2 of 3
CERTIFICATE OF SERVICE

I hereby certify that on this 12th day of March, 2012, I filed the foregoing Defendant John 

Gallegos’ Motion for Additional Two Weeks in which to File Motions with the Clerk of Court using 

the CM/ECF system. 

Linda Kaufman 

Assistant United States Attorney 

1225 17th Street, Ste 700 

Denver, CO 80202 

Martin Stuart 

Portman Stuart, LLC 

955 Bannock Street, Suite 200 

Denver, CO 80204 

Ph: 303-355-6789 

Fax: 303-623-0714 

Counsel for Ms. Weingart 

 /s/ Suzy M. Kamps 

 Suzy M. Kamps 

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