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¶