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1 1 (2021)

handle is hein.preview/supctlpi0001 and id is 1 raw text is: No. 18-1059 IN THE ftur Tiurt of tlir uitrd _§tatrli BRIDGET ANNE KELLY, Petitioner, V. UNITED STATES OF AMERICA et al., Respondents. On Writ of Certiorari to the United States Court of Appeals for the Third Circuit MOTION OF RESPONDENT IN SUPPORT OF PETITIONER WILLIAM E. BARONI, JR. FOR DIVIDED ARGUMENT Pursuant to Supreme Court Rule 28.4, Respondent in Support of Petitioner William E. Baroni, Jr. (Baroni) moves for oral argument to be divided such that counsel for Petitioner Bridget Anne Kelly (Kelly) would receive 20 minutes of argument time and counsel for Baroni would receive 10 minutes. Among other reasons, a division of time would be appropriate because (i) Baroni, not Kelly, is the public official whose authority to order a traffic study and/or realign the lanes onto the George Washington Bridge is the central issue on which the government asserts both defendants' criminal liability rises and falls; (ii) Baroni and Kelly emphasize different arguments in the case; and (iii) Baroni is a respondent in name only, having participated essentially as a petitioner at every stage in this Court while filing as a respondent solely to avoid the multi-month delay that filing his own petition would unnecessarily have occasioned. Accordingly, hearing argument from Baroni's own

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