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UNITED STATES COURT OF APPEALS

FOR THE FIRST CIRCUIT

Appeal No. 12-1236

IN RE: REQUEST FROM THE UNITED KINGDOM PURSUANT TO THE

TREATY BETWEEN THE GOVERNMENT OF THE UNITED STATES OF

AMERICA AND THE GOVERNMENT OF THE UNITED KINGDOM ON

MUTUAL ASSISTANCE IN CRIMINAL MATTERS IN THE MATTER OF

DOLOURS PRICE

UNITED STATES OF AMERICA,

Petitioner-Appellee

v.

TRUSTEES OF BOSTON COLLEGE, ET AL.,

Movants-Appellants

GOVERNMENTS MOTION FOR ORDER EXTENDING THE TIME

TO JULY 6, 2012

WITHIN WHICH IT MUST FILE ITS RESPONSIVE BRIEF

The government respectfully moves this Court to enter an order extending the

due date for the governments responsive brief by 31 days, to July 6, 2012. In

support of this motion, the government states the following:

1. This is Boston Colleges appeal from orders entered by the district court

in connection with subpoenas issued by the United States pursuant to a Mutual Legal

Assistance Treaty between the United States and the United Kingdom.

2. Boston College filed its brief on May 4, 2012, and the governments

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Case: 12-1236 Document: 00116387759 Page: 1 Date Filed: 06/05/2012 Entry ID: 564667


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brief is currently due on June 7, 2012. The government has not previously requested

an extension of its deadline.

3. This appeal raises potentially important questions regarding the district

courts application of the relevant legal standards in determining, through an in

camera review process, the documents within Boston Colleges custody and control

responsive to the United Kingdoms request.

4. The undersigned is currently involved in drafting the governments

responsive brief in the consolidated appeals United States v. Jones, 10-2495, and

United States v. Tavares, 10-1781, 11-1055, in which the defendants present a

number of challenges their convictions and sentences, after a 10-day trial, on charges

relating to child prostitution. The governments brief is currently due on June 8,

2012. Prior to that, the undersigned was involved in writing or reviewing briefs in

a number of other appeals, including, most recently, United States v. Massaro, No.

11-2067 (governments brief filed May 16, 2012), United States v. Sasso, No. 11-

1094 (governments brief filed May 18, 2012), and United States v. Gomez, No. 11-

1943 (governments brief filed May 21, 2012). As a result, the undersigned has not

been able to begin work on the governments response in this case.

5. Given the nature of the issues raised, the governments responsive brief

will need to be circulated for review to a number of governmental entities beyond the

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U.S. Attorneys Office and sufficient time is needed to incorporate any comments that

are received.

Respectfully submitted,

CARMEN M. ORTIZ

United States Attorney

By: /s/Randall E. Kromm

RANDALL E. KROMM

Assistant U.S. Attorney

Certificate of Service

I, Randall E. Kromm, AUSA, hereby certify that on June 5, 2012, I

electronically served a copy of the foregoing document on the following registered

participants of the CM/ECF system:

Jeffrey Swope, Esq.

Edwards Wildman Palmer LLP

111 Huntington Ave.

Boston, MA 02199

/s/Randall E. Kromm

RANDALL E. KROMM

Assistant U.S. Attorney

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