UNITED STATES DISTRICT COURT

FOR THE
DISTRICT OF NEW HAMPSHIRE

*************************
* *
* UNITED STATES OF AMERICA*
* *
* v. * 07-cr-189-03-GZS
* *
* CIRINO GONZALEZ *
* *
*************************

PARTIALLY ASSENTED MOTION FOR LEAVE TO FILE LATE

NOW COMES the defendant, Cirino Gonzalez, by counsel, David H. Bownes, and

respectfully request leave of the Court to file late Motions In Limine and the Exhibit List with

respect to the above-captioned matter.

As grounds for this request it is stated:

1. This counsel is not able to file a Motion In Limine by the deadline of 3/13/08 at 12:00

p.m. due to circumstance beyond this counsel’s control.

2. In addition, this counsel is not able to file an Exhibit List by the due date.

3. Counsel has spoken to the Assistant U.S. Attorney, Arnold Huftalen, and he is assents

to the granting of this request.

4. Counsel has spoken to Stanley Norkunas, Esq., counsel for co-defendant Jason

Gerhard, and he assents to the granting of this request.

5. Counsel has not contacted co-defendant, Daniel Riley, and his position is not known.

WHEREFORE the defendant requests that this Court grant said relief and for such

further relief as may be just.

 Respectfully Submitted,
Cirino Gonzalez,
By His Attorney,

LAW OFFICE OF DAVID H. BOWNES, P.C.

Dated: March 13, 2008 /S/ David H. Bownes, Esq.

David H. Bownes, Esq.
NH Bar No.: 277
486 Union Avenue
Laconia, NH 03246
(603) 524-4330
office@dhblaw.net

CERTIFICATION

I hereby certify that on this 13th day of March, 2008 that a copy of the foregoing Partially
Assented Motion for Leave to File Late has been forwarded to Arnold Huftalen, Esq., United
States Attorney’s Office, Paul Garrity, Esq,, and to Stanley Norkunas, Esq. via ECF and to
Daniel Riley at the Strafford House of Corrections via U.S. First Class Mail.

/S/ David H. Bownes, Esq.

David H. Bownes, Esq.