Free Motion for Extension of Time to File - District Court of Colorado - Colorado

Case 1:00-cr-00310-WYD

Document 424

Filed 05/10/2007

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UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Judge Wiley Y. Daniel Criminal Action No. 00cr00310WYD UNITED STATES OF AMERICA, Plaintiff, v. RICARDO GONZALEZ, Defendant.

UNOPPOSED MOTION FOR ENLARGEMENT OF TIME IN WHICH TO FILE MOTIONS

Ricardo Gonzalez, moves for an additional 30 days, up to and including June 10, 2007 to file additional pre-trial motions in this matter. As grounds of this motion Mr. Gonzalez states: 1. 2. Motions are currently due on May 11, 2007. The indictment alleges, among other things, a conspiracy that

lasted over four years. Discovery provided is in excess of six thousand pages. 3 The government has provided the discovery on a compact disc.

Unfortunately, because the case is so old the format of disc is also very old. The disc is not searchable. The materials on the disc do not appear to be organized in any meaningful fashion. Review of the discovery in its current state is extremely time-consuming. As a result, counsel has contacted S Corporation to

Case 1:00-cr-00310-WYD

Document 424

Filed 05/10/2007

Page 2 of 3

have the materials put on LaserFische.1 Counsel has been advised that the conversion should be completed by no later than May 21, 2007. 4. Counsel believes that the discovery can be reviewed much more

quickly in the searchable LaserFische format and that sufficient review can occur allowing motions to be filed by June 10, 2007. 5. Mr. Gonzalez has filed additional motions with the court which will

continue to toll speedy trial pursuant to 18 U.S. C. 3161 (h)1)(F). 6. Counsel has discussed this matter with AUSA Jim Boma who has authorized counsel to represent to the court that he has no objection to the requested relief. Respectfully submitted, s/ Mitchell Baker______ Mitchell Baker Attorney for Defendant Gonzalez 1543 Champa Street, Suite 400 Denver, CO 80202 (303)592-7353 [email protected]

Counsel has been advised that cost of simply converting the discovery to LaserFische without any additional labeling or organizing will not exceed $500.00 so no pre- authorization has been sought.

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Case 1:00-cr-00310-WYD

Document 424

Filed 05/10/2007

Page 3 of 3

CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 10th day of May, 2007, I electronically filed the foregoing with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following e-mail address:
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Richard James Banta [email protected],[email protected] James R. Boma [email protected],[email protected],[email protected] ov J. Michael Dowling [email protected] Dennis W. Hartley [email protected] Neil E. MacFarlane [email protected] John F. Sullivan , III [email protected]