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United States v. Leopard

United States District Court, D. Nevada

March 15, 2019

UNITED STATES OF AMERICA, Plaintiff,
v.
MARKO LEOPARD, Defendant.

          ANGELA H. DOWS, ESQ., PREMIER LEGAL GROUP, Attorney for Defendant Marko Leopard

          DAVID 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 Plaintiff

          DEFENDANT MARKO LEOPARD'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE REPLIES TO HIS MOTIONS TO DISMISS

         Certification: This pleading is timely filed.

         Defendant 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).

         MEMORANDUM OF POINTS AND AUTHORITIES

         1. On 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.]

         2. Mr. 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 initial appearance.

         3. On 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. 471).

         4. On March 4, 2019, the government filed a combined Response to Mr. Leopard's Motions to Dismiss (ECF No. 502).

         5. That 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.]

         6. Mr. 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 schedule.

         7. On or about March 11, 2019, instant counsel mailed the government's response(s) to Mr. Leopard for review.

         8. 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.

         9. Instant counsel thus requests additional time to be able to adequately confer with Mr. Leopard prior to filing ...


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