Free Motion to Continue Trial - District Court of Arizona - Arizona

1 Gnonen F. KLLNK J
45 West Jefferson FRED ..__ LODGE;)
2 Luhrs Tower - Suite #810 -..... RECEIVED ____COpY
Phoenix, AZ 85003-2328
3 §i‘$i2iii‘i3i3057 "’“" 21 2°°’
4 Attorney for Defendant c[_%}g(T;g"% COURT
5 il "'ii‘;li;;.i;;,·;·_;·;;;g;-;·~—P
6 N THE UNITED STATES DISTRICT COURT
7 DISTRICT OF ARIZONA
8
9 United States of America, l No. CR04-00675—002-PHX—JAT
10 Plaintiff, ) MOTION TO CONTINUE TRIAL
) AND EXTEND TIME TO FILE
ll v. ) PRETRIAL MOTIONS
12 Pete Jesse Cardenas, g (Filed Under Seal)
13 Defendant. g (Third Request)
_ 14
15 Defendant, Pete Jesse Cardenas, by and through counsel undersigned, respectfully requests that
16 the Court continue the trial cuirently set for May l, 2007, for a period of at least 45 days, for the
17 following reasons:
18 l. There is extensive discovery in this case, all of which has yet to be made available by the
19 government. ` _
20 2. Undersigned counsel needs additional time in which to prepare this case for trial. Counsel
21 needs additional time in which to conduct the investigation in order to provide effective assistance of
22 counsel as mandated by the Sixth Amendment.
23 The government, by Assistant United States Attorney, Brian Larson, does not oppose this
24 request.
25 For the above stated reasons, counsel needs additional time in order to provide the effective
26 assistance of counsel mandated by the Sixth Amendment of the Constitution ofthe United States and,
27 therefore, a continuance of the trial and an extension of time to file pretrial motions is requested.
28 This motion is brought in good faith for the reasons stated and not for the purpose of delay.
Case 2:04-cr—00675-JAT Document 292 Filed 05/21/2007 Page 1 of 2

1 EXCLUDABLE DELAY pursuant to 18 U.S.C. §3161(h)(8)(A) and (h)(l)(P) may result from
2 this motion and any order entered.
3 Respectfully submitted this 17*** day 0f May, 2007.
4
5 4 c~
GEORGE INK
6 Attorney or Defendant
7 Copy of the fore%1oing mailed!
delivered this 17 day of May,
8 2007 to:
9 Hon. James A. Teilborg
United States District Court
10 401 West Washington Street
Phoenix, AZ 85003
11
Brian G. Larson
12 Assistant U.S. Attorney
Two Renaissance Square
13 40 North Central Avenue, Suite 1200
Phoenix, A 85004
1 5 hx
is ` 2
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Case 2:04-cr-00675-JAT

Document 292

Filed 05/21/2007

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Case 2:04-cr-00675-JAT

Document 292

Filed 05/21/2007

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