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2. This Motion is not made for any improper purpose but only to ensure a fair and just

disposition of Defendant Kesharis Motion.

3. The undersigned has contacted counsel for Defendant Keshari who has indicated that

he does not oppose this Motion.

For the foregoing reasons, the United States respectfully requests that this Court enter an

order granting the United States leave to file a twenty-six page Memorandum, which is being filed

concurrently herewith.

Respectfully submitted,

R. ALEXANDER ACOSTA

UNITED STATES ATTORNEY

By: S/ Melissa Damian

Melissa Damian

Assistant United States Attorney

Florida Bar No. 0068063

99 Northeast 4th Street

Miami, Florida 33132-2111Tel: (305) 961-9018

Fax: (305) 536-4675

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CERTIFICATE OF SERVICE

I hereby certify that on August 7, 2008, I electronically filed the foregoing with the Clerk

of the Court by using the CM/ECF system which will send a notice of electronic filing to David O.

Markus, counsel for Defendant Hassan Saied Keshari.

S / M e l i s s a D a m i a n

Melissa Damian

Assistant United States Attorney

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