United States District Court, D. Nevada
H. DOWS, ESQ., PREMIER LEGAL GROUP, Attorney for Defendant
A. JAFFE Chief, Organized Crime and Gang Section KELLY
PEARSON Deputy Chief, Organized Crime and Gang Section CHAD
W. MCHENRY ALEXANDER GOTTFRIED Trial Attorneys, Organized
Crime and Gang Section U.S. Department of Justice Counsel for
DEFENDANT MARKO LEOPARD'S UNOPPOSED MOTION FOR
EXTENSION OF TIME TO FILE REPLIES TO HIS MOTIONS TO
This pleading is timely filed.
Marko Leopard through his counsel Angela H. Dows, Esq.,
respectfully requests that this Court grant Defendant an
extension of time of seven (7) days or until on or before
March 26, 2019 to file his reply briefs to his: (1) Motion to
Dismiss Based Upon Fifth Amendment Double Jeopardy and Lack
of Due Process of Law (ECF No. 468), and (2) Motion to
Dismiss Count One as Unconstitutionally Overbroad and/or
Vague (ECF No. 471).
OF POINTS AND AUTHORITIES
January 30, 2018, a grand jury in the District of Nevada,
United States of America, returned a Second Superseding
Indictment against Mr. Leopard and thirty-five others. The
Second Superseding Indictment charged Mr. Leopard with
Racketeering Conspiracy, in violation of 18 U.S.C. §
1962(d). [See Dkt. No. 303.] Specific allegations
were that Mr. Leopard became a member of the Infraud
Organization in June of 2011, and that he operates
"Abuse Immunity" or "Bulletproof Hosting"
services that Organization members can employ to create,
operate, maintain and protect their own online contraband
stores. [See Dkt. No. 303, a, 'page 18.]
Leopard made his initial appearance in the case in October of
2018. [See ECF No. 420.] Instant counsel was
appointed for Mr. Leopard at Mr. Leopard's October 2018
February 1, 2019, Mr. Leopard filed a Motion to Dismiss Based
Upon Fifth Amendment Double Jeopardy and Lack of Due Process
of Law (ECF No. 468), as well as a Motion to Dismiss Count
One as Unconstitutionally Overbroad and/or Vague (ECF No.
March 4, 2019, the government filed a combined Response to
Mr. Leopard's Motions to Dismiss (ECF No. 502).
the current reply briefs deadline in the case is March 19,
2019, and trial is currently set for October of 2019.
[See ECF No. 405.]
Leopard is currently incarcerated pending trial at the Nevada
Southern Detention Center in Pahrump, Nevada. Said facility
is approximately 1.5 hours of driving time each way from Las
Vegas, Nevada, and takes some lead time to accomplish and
or about March 11, 2019, instant counsel mailed the
government's response(s) to Mr. Leopard for review.
Instant counsel will be visiting Mr. Leopard the week of
March 18, 2019 to confer in-person and in part as to the
government's filed response(s), without revealing the
substance of said communications.
Instant counsel thus requests additional time to be able to
adequately confer with Mr. Leopard prior to filing ...