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

1 JON M. SANDS Federal Public Defender 2 850 West Adams, Suite 201 Phoenix, Arizona 85007 3 Telephone: (602) 382-2721 4 JEANETTE E. ALVARADO #016111 Asst. Federal Public Defender 5 Attorney for Defendant [email protected] 6 7 8 9 10 11 12 13 14 15 vs. Robert Shinn, et al., Defendant. Robert Shinn, through undersigned counsel, respectfully requests that United States of America, Plaintiff, No. CR-04-0820-PHX-FJM MOTION TO EXTEND PRETRIAL MOTIONS (Fourth Request) IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA

16 this Court extend the time for filing of pretrial motions for a period of at least thirty 17 (30) days from the date of September1, 2005. The reason for the continuances is to 18 allow additional time for investigation. Defense counsel has contacted Assistant United States Attorney, Gary 19 20 Restaino, concerning this motion and he has no objection to the requested 21 continuances. 22 Bruce Blumberg, counsel for Harvey L. Soliniker, Jr., Thomas Hoidal, 23 Esq., counsel for co-defendant John Desiderio. Michael Bresnehan, Esq., counsel for 24 Kindy Jonagan, and Ivan Mathew, Esq., counsel for co-defendant Richard Nail, do not 25 oppose this motion. Gregory Parzych, Esq., counsel for co-defendant Tye Sloniker, 26 was contacted but was not available to obtain his concurrence as to the filing of this 27 motion. 28

Case 2:04-cr-00820-FJM

Document 128

Filed 09/28/2005

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1 3 thereon. 4 5 6 7 8 9

It is expected that excludable delay under Title 18 U.S.C. Section

2 3161(h)(8)(A) and (h)(1)(F) may result from this motion or from an order based Respectfully submitted: September 28, 2005. JON M. SANDS Federal Public Defender s/Jeanette E. Alvarado JEANETTE E. ALVARADO Asst. Federal Public Defender

Copy of the foregoing transmitted 10 by CM/ECF this 28th day of September, 2005, to: 11 GARY RESTAINO 12 & RACHEL HERNANDEZ Assistant United States Attorney 13 Two Renaissance Square 40 North Central Avenue 14 Suite 1200 Phoenix, Arizona 85004-4408 15 BRUCE E. BLUMBERG, ESQ. 16 THOMAS HOIDAL, ESQ. 17 MICHAEL J. BESNEHAN, ESQ. 18 IVAN KURIAN MATHEW, ESQ. 19 GREGORY PARZYCH 20 Copy mailed to: 21 ROBERT SHINN 22 Defendant 23 25 26 27 28 2 s/Jeanette E. Alvarado 24 JEANETTE E. ALVARADO
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Case 2:04-cr-00820-FJM

Document 128

Filed 09/28/2005

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