Case 0:13-cr-60240-WPD Document 71 Entered on FLSD Docket 04/21/2014 Page 1 of 2

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 13-60240-CR-DIMITROULEAS

UNITED STATES OF AMERICA, Plaintiff, v. RICHARD ALTOMARE, Defendant. _______________________________/ UNOPPOSED MOTION TO EXTEND TIME TO FILE PSI OBJECTIONS Defendant, Richard Altomare, through undersigned counsel and pursuant to Fed. R. Crim. P. 32, requests that the Court extend the time for filing objections to the presentence report by 7 days to April 28, 2014 and in support of the motion states: 1. Undersigned counsel assumed the role of lead counsel for sentencing upon filing of

his notice of appearance on April 10, 2014 and has provided the presentence report to the defendant and obtained the defendants comments and proposed amendments to the report. Counsel has prepared and provided to the government and the probation officer initial objections, but seeks additional time to conduct further research and review to determine the applicability of guideline enhancements and potential reductions from the presently calculated guideline range and to assure that all relevant issues are addressed. 2. Undersigned counsel was required to commence a two-week federal jury trial in

Orlando, Florida on April 14, 2014 on a 5-days-per-week schedule in a complex mortgage fraud prosecution. Due to the demands of trying the Orlando case, counsel has been unable to finalize his

Case 0:13-cr-60240-WPD Document 71 Entered on FLSD Docket 04/21/2014 Page 2 of 2

objections to the report and therefore seeks an additional 7 days, to April 28, 2014, in which to filed objections to the presentence report. 3. Counsel for the government, Assistant United States Attorney Alejandro Soto, has

authorized undersigned counsel to represent that the government does not oppose the relief sought by this motion. WHEREFORE, Defendant Richard Altomare requests that the Court extend the time for filing objection to the presentence investigation report until April 28, 2014. Respectfully submitted, /s/ John E. Bergendahl John E. Bergendahl, Esq. Fla. Bar No. 327761 25 S.E. 2nd Avenue, Suite 1100 Miami, Florida 33131 Tel. (305) 536-2168 Fax (305) 536-2170 E-Mail lojeb1100@gmail.com

CERTIFICATE OF SERVICE I HEREBY certify that on April 21, 2014 , I electronically filed the foregoing document

with the Clerk of the Court using CM/ECF. /s/ John E. Bergendahl John E. Bergendahl, Esq.