Free Motion to Extend Time to File Pretrial Motions - District Court of Arizona - Arizona

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MARK PAIGE 111 West Monroe Suite #1212 Phoenix, AZ 85003-2317 (602) 254-5457 State Bar #020902 [email protected] Attorney for Defendant

UNITED STATES DISTRICT COURT 7 8 9 10 11 12 13 14 The defendant, Jesse Moore, by and through counsel respectfully moves the Court to stay 15 the presently set motion deadline of January 25, 2008 and, upon notice from the parties, extend 16 the deadline for pretrial motions on the following grounds: 17 1. The defendant is charged by Indictment with murder. The defendant was previously 18 indicted and tried. After conviction and sentencing an appeal was filed and heard by the 19 Ninth Circuit. As a result of that appeal this matter was remanded for a new trial. 20 2. The parties have discussed and seem to be near a resolution in this matter. The defense 21 is awaiting a written plea agreement memorializing the discussions had to date. Upon 22 receipt, and after any necessary discussions regarding language and/or other terms, the 23 document will need to be reviewed with the defendant. Counsel anticipates receipt of this 24 document later this week or early next week. 25 3. Therefore, the defendant requests that the present deadline be stayed. Should the 26 parties fail to reach an agreement, counsel for the parties will notify the Court and a new 27 motion deadline can be set. Counsel expects this delay to require no more that two to 28 DISTRICT OF ARIZONA _______________________________________ ) UNITED STATES, ) No.: CR-03-764-PHX-JAT ) Plaintiff, ) ) DEFENDANT'S MOTION TO v. ) STAY AND EXTEND ) PRETRIAL MOTIONS DEADLINE Jesse Moore, ) ) Defendant. ) (First Request) _______________________________________)

Case 2:03-cr-00764-JAT

Document 1244

Filed 01/16/2008

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three weeks. 4. This defendant is in custody. Counsel for the Government, Kimberly Hare, has no objection to this request. The defendant requests a stay and extension of this pretrial motion deadline to allow undersigned counsel to be prepared and able to render effective assistance of counsel consistent with the Sixth Amendment guarantee for every defendant.

Respectfully submitted this 16th day of January, 2008. S/ Mark A. Paige MARK PAIGE Attorney for Defendant I hereby certify that on January 16, 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: Kimberly Hare Assistant U.S. Attorney [email protected] S/ Mark A. Paige Mark A. Paige

Case 2:03-cr-00764-JAT

Document 1244

Filed 01/16/2008

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