Free Motion for Leave to File Excess Pages - District Court of Arizona - Arizona

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Brian F. Russo, Esq. AZ Bar No. 018594 111 West Monroe Street Suite 1212 Phoenix, Arizona (602) 340-1133 telephone (602) 258-9179 facsimile e-mail: [email protected] Attorney for Defendant Robert Johnston Jr. IN THE UNITED STATES DISTRICT COURT IN AND FOR THE DISTRICT OF ARIZONA UNITED STATES OF AMERICA, Plaintiff, vs. ROBERT J. JOHNSTON, JR. (1), Defendant. ) ) ) ) ) ) ) ) ) ) Case No. CR 03-1167 PHX-DGC MOTION TO EXCEED PAGE LIMITS ON DEFENDANT'S MOTION TO DISMISS RE: FAILURE TO COMPLY WITH DISCLOSURE OBLIGATIONS

COMES NOW the defendant Robert Johnston, by and through counsel, Brian F. Russo, and on behalf of all other defendants and hereby moves this honorable Court for an order that the Defendant's Motion to Dismiss be allowed to exceed the page limits by two pages. Defendant's Motion is very fact specific and relies on quotes from Interviews conducted with agents involved in the investigation of the case. Many of the quotes are cited throughout and in support of the Motion. Defendant asserts that the additional pages are necessary to presenting Defendant's Motion in the most comprehensive and effective manner

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Case 2:03-cr-01167-DGC

Document 927

Filed 12/07/2005

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RESPECTFULLY SUBMITTED this 7th day of December, 2005.

/s/ Brian F. Russo Brian F. Russo Attorney for Defendant

COPY of the foregoing electronically mailed / delivered this 7th day of December, 2005, to: Tim Duax Keith Vercauteran Assistant U.S. Attorney All Defense Counsel

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/s/
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Case 2:03-cr-01167-DGC

Document 927

Filed 12/07/2005

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