Free Motion to Extend Time to File Pretrial Motions - 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 Jefferson, Suite 210 Phoenix, Arizona 85003

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) Case No: 04-CR-820-PHX-FJM ) ) MOTION TO EXTEND TIME TO FILE ) PRETRIAL MOTIONS ) ) (First Request) ) ) ) )

COMES NOW, Defendant, Harvey Sloniker, by and through undersigned counsel, and respectfully requests that this Honorable Court for an Order extending the time limit for filing motions for a period of thirty days for the reasons set forth more fully below. 1. Discovery in this matter is voluminous. 2. The issues are complex and additional time is required to explore all issues. Assistant United States Attorney, Rachel Hernandez has indicated that she has no objection to this motion. Defense Counsel for co-defendants have been contacted and have no objection to this motion. An attempt to contact co-defendant Shinn's attorney, Jeannette Alvarado was made however she is out of the office until September 6, 2005. 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.

Case 2:04-cr-00820-FJM

Document 104

Filed 08/31/2005

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BLUMBERG & ASSOCIATES

WHEREFORE, defendant Harvey Sloniker, respectfully requests the time limit for filing motions be extended for a period of thirty days.

RESPECTFULLY SUBMITTED, this 31st day of August, 2005.

BLUMBERG & ASSOCIATES

By:

s/ Bruce Blumberg

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45 West Jefferson, Suite 210 Phoenix, Arizona 85003

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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 Parzychand the Honorable Frederick Martone.

Case 2:04-cr-00820-FJM

Document 104

Filed 08/31/2005

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