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IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OP VIRGINIA
UNITED STATES OF AMERICA,
LYNDON H. LAROUCHE, JR., et al.
Cr. No. 88-00243-A
MEMORANDUM IN SUPPORT OF MOTION OF DEFENDANTS LAROUCHE, WERTZ, SPANNAUS,
BILLINGTON, SMALL AND TO EXTEND
ASSIGNMENT TO THE ALEXANDRIA DETENTION CENTER
IN VIRGINIA PENDING SUBMISSION OF BRIEFS ON APPEAL
On May 8, 1989, this Court granted the above-named defendants' unopposed motion to remain incarcerated in the Alexandria Detention Center until and including June 30, 1989. The purpose behind defendants' motion was to permit them to assist their counsel in the preparat ion of appropriate papers in connect ion with their appeal to the United States Courts of Appeals for the Fourth Circuit.
Due to two minor, previously unanticipated, time continuances granted to both parties, the government now anticipates filing its opposition brief on June 23, 1989. As a result, the final brief in this matter — Appellants' Reply Brief — will not be due unti1 approximately the first or second week of July, 1989, i.e., anywhere between ten (10) to fourteen (14) days after the expiration of the Court's May 8, 1989 Order.
Since their incarceration in the Alexandr ia Detent ion Center, the above-named defendants have actively participated in the
preparation of various motion papers as well as the merits appellate brief. This assistance has proven to be invaluable, making defendants' involvement in the Reply Brief an absolute must for defense counsel.
Assistant United States Attorney Kent Robinson has authorized the undersigned to represent that the government joins in this motion.
For the foregoing reasons, the above-named defendants respectfully request this Court to grant their motion to extend assignment to the Alexandria Detention Center for an additional fourteen (14) days, to and including July 14, 1989.
Dated: June 21, 1989
SHAW, PITTMAN, POTTS & TROWBRIDGE
R. Kenly Webster, P.C. Thomas C. Hill, P.C. Gadi Weinreich 2300 N Street, N.W. " Washington, D.C. 20037 (202) 663-8000
Counsel for Edward Spannaus and on behalf of all the above-named defendants
CERTIFICATE OF SERVICE
I hereby certify that on the ^>sr day of June 1989, a copy of the Motion of Defendants LaRouche, Wertz, Spannaus, Billington, Small and } to Extend Assignment to the Alexandria Detention Center in Virginia Pending Submission of Briefs on Appeal, Memorandum of Points and Authorities in Support thereof, and proposed Order were served by United States Mail, postage prepaid, on
Kent S. Robinson Assistant U.S. Attorney U.S. Courthouse Rm 312 620 Southwest Main Street Portland, Oregon 97205