# Document EFTA 02845848



# The Law Offices of MONTELL FIGGINS u\_c
17 Academy Street. Suite 305 Newark New Jersey 07102 Phone: (973) 242-4700 Fax: (973) 242-4701 www.ligginslaw.com BRANCH OFFICES:

140 East Ridgewood Avenue Paramus, NJ 07640

# Reply to Newark Office [X]
# ASSOCIATu\_
Kenneth E. M. Esq. Linda Childs. Esq.

# SENT VIA ECF
Honorable Analisa U.S. Southern District of NY 500 Pearl Street New York, NY 10007

30 WWI Street S. Floor New Yak, NY 1005

March 20, 2020

Re: State of NY v Michael et al. Docket No.: 1:19-cr-00830 Request Extension to File Motion

Dear Judge

As you are aware, our firm represents the Defendant, Michael M, in the abovecaptioned matter. Pursuant to Your Honor's Order, our firm's motion to dismiss was due today, March 20, 2020, however, we are requesting a fourteen (14) day extension in which to file our motion. Needless to say, the current events with respect to the pandemic affecting the country, has drastically affected my staffs work hours, as well as my ability to complete this motion while still managing other issues associated with my business and my family.

In light of the foregoing, the Defendants, by and through the undersigned, respectfully requests a 14 day extension to file its motion to dismiss.

Respectfully submitted,

/s/ Montell Figgins

Montell Figgins, Esq.

Attorney for Defendant Michael

MF/sf