Free Motion to Continue - District Court of Arizona - Arizona

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BLUMBERG & ASSOCIATES

Bruce E. Blumberg
BLUMBERG & ASSOCIATES
_____________________

45 West Jefferson, Suite 210 Phoenix, Arizona 85003
Office: (602) 277-6180 Fax: (602) 271- 4119

Attorney for Defendant Arizona State Bar Number 010779

UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA

UNITED STATES OF AMERICA, Plaintiff, vs. HARVEY SLONIKER., Defendant

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45 West Jef ferson, Suite 210 Phoenix, Arizona 85003

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) Case No: 04-CR-820-PHX-FJM ) ) MOTION TO CONTINUE TRIAL ) ) ) (Third Request) ) ) ) )

COMES NOW, Defendant, Harvey Sloniker, by and through undersigned counsel, and respectfully requests that this Honorable Court enter an Order continuing the trial currently set in this matter on February 7, 2006, for a period of sixty days for the reason that on December 2, 2005, the government disclosed an additional 1,000 plus pages of discovery pertaining to the government's key witnesses and their statements. The information contained in this most recently disclosed discovery requires additional time to thoroughly assess. The new discovery is much more relevant and informative than previous disclosures. Additional time is necessary to prepare an adequate defense. 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 of from an Order based thereon. WHEREFORE, defendant Harvey Sloniker, respectfully requests the trial in matter be continued for a period of 60 days.

Case 2:04-cr-00820-FJM

Document 193

Filed 12/09/2005

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BLUMBERG & ASSOCIATES

RESPECTFULLY SUBMITTED, this 9th day of December, 2005.

BLUMBERG & ASSOCIATES

By:

s/ Bruce Blumberg

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 to the following CM/ECF registrants: Michael Bresnehan, Rachel Hernandez, Gary Restaino, Jeanette Alvardo, Thomas Hoidal, Ivan Mathew, Gregory Parzych and the Honorable Frederick Martone.

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45 West Jef ferson, Suite 210 Phoenix, Arizona 85003

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Case 2:04-cr-00820-FJM

Document 193

Filed 12/09/2005

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