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

1 LAW OFFICES OF MICHAEL J. BRESNEHAN, P.C. Michael J. Bresnehan, Esquire 2 1761 East McNair Drive, Suite 101 Tempe, AZ 85283-5002 3 480-345-7032 [email protected] 4 State Bar No.: 009415 5 Attorney for Defendant 6 7 8 9 10 11 vs. 12 KINDY JONAGAN, 13 14 Defendant. COMES NOW, Defendant, Kindy Jonagan, by and through undersigned attorney, and United States of America, Plaintiff, IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA Case No.: CR-04-0820-PHX-FJM MOTION TO EXTEND TIME TO FILE PRETRIAL MOTIONS (First Request)

15 hereby requests an Order extending the time limit for filing pretrial motions for a period of thirty 16 17 18 19 20 1. Discovery in this matter is voluminous (over 300,000 documents). 2. The issues are complex, and additional time is required to identify and explore all issues. Assistant United States Attorney Rachel Hernandez has indicated that she has no objection (30) days for the reasons set forth more fully below:

21 to this motion. The government, through Rachel Hernandez and Gary Restaino, does not object to 22 the relief sought herein. Jeanette E. Alvarado, counsel for co-defendant, Robert Shinn, does not 23 24 25 26 27 oppose the filing of this motion and would join in this motion. It is expected that excludable delay under Title 18 U.S.C. Section 3161(h)(1)(F) may occur as a result of this motion or from an Order based thereon. WHEREFORE, defendant, Kindy Jonagan, respectfully requests that the time limit for filing

28 motions be extended for a period of thirty (30) days. Case 2:04-cr-00820-FJM Document 106 Filed 09/01/2005 Page 1 of 2

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RESPECTFULLY SUBMITTED, this 1st day of September, 2005. MICHAEL J. BRESNEHAN, P.C.

s/ Michael J. Bresnehan Michael J. Bresnehan Attorney for Defendant CERTIFICATE OF SERVICE

I hereby certify that on this date, 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 9 to the following CM/ECF registrants: Bruce Blumberg, Rachel Hernandez, Gary Restaino, Jeanette 10 Alvardo, Thomas Hoidal, Ivan Mathew, Gregory Parzych and the Honorable Frederick Martone. 11 12 s/ Michael J. Bresnehan 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Case 2:04-cr-00820-FJM Document 106 2Filed 09/01/2005 Page 2 of 2