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

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— _ FILED IDDGED
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1 Giioncr: F. KLINK
45 West Jefferson APR 0 2 2007
2 L\1hl"S Tower - SllitB CLERK U S D|ST[;“G’[ COURT
Phoenix, AZ 85003-2328 DIsrAIct os AaI20I¤IA
3 (602) 253-3889 evg_______,Â¥ DEPUTY
State Bar #004057 ""_”“
4 Attorney for Defendant
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IN THE UNITED STATES DISTRICT COURT
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DISTRICT OF ARIZONA AL W
7 ED
8 )
United States of America, ) No. CRO4-00675-002-PHX-JAT
9 )
Plaintiff, ) MOTION TO CONTINUE TRIAL
10 ) AND EXTEND TIME TO FILE
v. ) PRETRIAL MOTIONS
11 )
I Pete Jesse Cardenas, ) (Filed Under Seal)
12 )
Defendant. ) (Second Request)
13 I
14 Defendant, Pete Jesse Cardenas, by and through cotmsel undersigned, respectfully requests that
15 the Court continue the trial currently set for May 1, 2007 for the following reasons:
l6 1. There is extensive discovery in this case, all of which has not yet been made available by the
17 government.
18 2. Undersigned counsel needs additional time in which to prepare this case for trial. Counsel
19 needs additional time in which to conduct the investigation in order to provide effective assistance of
20 counsel as mandated by the Sixth Amendment.
21 The government, by Assistant United States Attomey, Brian Larson, does not oppose this
22 request.
23 For the above stated reasons, counsel needs additional time in order to provide the effective
24 assistance of counsel mandated by the Sixth Amendment of the Constitution of the United States and,
25 therefore, a continuance of the trial and an extension of time to file pretrial motions is requested.
26 This motion is brought in good faith for the reasons stated and not for the purpose of delay.
27 EXCLUDABLE DELAY pursuant to 18 U.S.C. §316l(h)(S)(A) and (h)(I)(F) may result from
28 this motion and any order entered.
Case 2:04-cr-00675-JAT Document 286 Filed O4/O2/2007 Page 1 of 2

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2 Respectfully submitted this 2“d day of April, 2007.
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By:
5 GEORG F. KLINK
Attorne for Defendant
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7 Copy of the foregoing mailed!
delivered this 2" day of April,
8 2007 to:
9 Hon. James A. Teilborg
United States District Court
10 401 West Washington Street
Phoenix, AZ 85003
1 1
Brian G. Larson
12 Assistant U.S. Attomey
Two Renaissance Square
13 40 North Central Avenue, Suite 1200
Phoenix, AZ 85004
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By:
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Case 2:O4—cr—OO675-JAT Document 286 _2FiIed O4/O2/2007 Page 2 of 2

Case 2:04-cr-00675-JAT

Document 286

Filed 04/02/2007

Page 1 of 2

Case 2:04-cr-00675-JAT

Document 286

Filed 04/02/2007

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