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

1 2 3 4

DAVID EISENBERG 331 N. First Avenue Suite 108 Phoenix, Arizona 85003 Arizona State Bar No. 017218 Telephone: (602) 452-2932 Email: [email protected]

UNITED STATES DISTRICT COURT 5 DISTRICT OF ARIZONA 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 United States of America, CR-03-0838-PHX-ROS Plaintiff, v. Sheri Blackburn, Defendant. (First Request) Defendant Sheri Blackburn, by and through the undersigned, respectfully submits the Defendant's Motion to Continue Trial and to Extend Time to File Pretrial Motions (First Request). Defendant requests that the Court enter an Order setting the date for trial sixty (60) days from the current trial date, which is June 3, 2008. Defendant further requests that the Court continue the date by when pretrial motions must be submitted sixty (60) days from the current date, which was May 5, 2008. The grounds for this request are that counsel for the Defendant received the discovery in this case on April28, 2008, which consists of approximately 336 pages, including the investigative agent's report, statements of bank accounts, bank transaction records and other financial records and reports. Although this does not appear to be a complex case in the sense of Local Rule 16.4 and 18 U.S.C. § 3161(h)(8)(B)(ii), it still requires a good deal of effort to prepare. The Assistant U. S. Attorney assigned to this case, Howard D. Sukenic, has informed the undersigned that he has no objection to a continuance for sixty (60) days for the date set for trial and for sixty (60) days for the date by when pretrial motions must be submitted. It is expected that excludable delay pursuant to Title 18, United States Code, Section 3161(b)(1)(F) may occur as a result of this motion or from an order based thereon.. / DEFENDANT'S MOTION TO CONTINUE TRIAL AND TO EXTEND TIME TO FILE PRETRIAL MOTIONS

Case 2:03-cr-00838-ROS

Document 13

Filed 05/08/2008

Page 1 of 2

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

Respectfully submitted this 8 th day of May, 2008.

s/ David Eisenberg DAVID EISENBERG
I hereby certify that on May 8, 2008, I electronically transmitted the attached document to the Clerk's Office using the CM/ECF System for filing and transmittal of a Notice of Electronic Filing to the following CM/ECF registrants: Howard D. Sukenic, Esq. Assistant U. S. Attorney Counsel for the United States of America

s/ David Eisenberg David Eisenberg

2

Case 2:03-cr-00838-ROS

Document 13

Filed 05/08/2008

Page 2 of 2