GuanHua Corporation (GHGH)

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UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS
____________________________________
Criminal No. 12-CR-10014-DPW
UNITED STATES OF AMERICA v MUHAMMAD (“M.J.”) SHAHEED, Defendant

GOVERNMENT’S MOTION FOR ENLARGEMENT OF TIME TO FILE
OPPOSITION TO DEFENDANT’S MOTION TO STAY SENTENCE
OR FOR BAIL PENDING APPEAL

The United States, through undersigned counsel, respectfully requests a two dayenlargement of time, until July 24, 2013, in which to file its Opposition to the defendant’s Motion to Stay Sentence or for Bail Pending Appeal, Dkt. No. 139. The government’s opposition is is currently due on July 22. Shaheed is not scheduled to report to the Bureau of Prisons to begin serving the sentence that is the subjection of his Motion until August 23, 2013.

As grounds for this Motion, the government states that undersigned counsel has been away from the office and her co-counsel has been in the midst of preparing for trial of another matter. The additional two days is necessary to allow counsel to respond to the defendant’s Motion while also attending to her other work obligations. As the defendant is not scheduled to begin serving his sentence until August 23, the government is hopeful that the requested brief enlargement of time will not interfere with the Court’s ability to address the defendant’s Motion in advance of that date.
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