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

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i 2 (602) 253-3889 MAR 1 9 2007
4 iligigegyrfigoggfgndant [ CLERK U S Dl$TFilCT COURT
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IN THE UNITED STATES DISTRICT COURT
6 DISTRICT OF ARIZONA
’ .._ SEALED
8 United States of America, 3 No. CR04-00675-002-PHX·JAT
9 Plaintiff, i MOTION TO CONTINUE TRIAL
10 ) AND EXTEND TIME TO FHJE
v. ) PRETRIAL MOTIONS
1 1 Pete Jesse Cardenas, ) (Filed Under Seal)
` Defendant. 3 (First Request) -
_ 14 Defendant, Pete Jesse Cardenas, by and through counsel undersigned, respectfullyrequests that
15 the Court continue the trial currently set for April 3, 2007 for the following reasons:
· 16 l. Discovery has not yet been made available by the government.
17 2. Undersigned counsel needs additional time in which to prepare this case for trial. Counsel
18 needs additional time in which to conduct the investigation in order to provide effective assistance of
19 counsel as mandated by the Sixth Amendment.
20 The government, by Assistant United States Attorney, Brian Larson, does not oppose this
21 request. _
22 For the above stated reasons, counsel needs additional time in order to provide the effective
23 assistance of counsel mandated by the Sixth Amendment of the Constitution of the United States and,
24 therefore, a continuance of the trial and an extension of time to tile pretrial motions is requested.
- 25 This motion is brought in good faith for the reasons stated and not for the purpose of delay.
26 EXCLUDABLE DELAY pursuant to 18 U.S.C. §3 l 6l(h)(8)(A) and (h)(I)(F) may result from
27 this motion and any order entered.
28 A
Case 2:04-cr-00675-JAT Document 283 Filed O3/19/2007 Page 1 of 2

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1 Respectfully submitted this 19* day of March, 2007.
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By: .
4 a GEORGE . KLINK
- Attorney for Defendant
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6 Copy of the foregloing mailed! l
1 delivered this 19 day of March,
7 2007 to:
8 Hon. James A. Teilborg
United States District Court _
9 401 West Washington Street
Phoenix, AZ 85003
10 . ·
Brian G. Larson
11 Assistant U.S. Attorney
Two Renaissance Square
12 40 North Central Avenue, Suite 1200
Phoenix, AZ 85004
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Case 2:04-cr-00675-JAT Document 28I32_ Filed O3/19/2007 Page 2 of 2

Case 2:04-cr-00675-JAT

Document 283

Filed 03/19/2007

Page 1 of 2

Case 2:04-cr-00675-JAT

Document 283

Filed 03/19/2007

Page 2 of 2