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 TEDDY LEE LOWE, 13 14 15 The defendant, Teddy Lee Lowe, by and through the undersigned counsel, moves this Defendant. United States of America, Plaintiff, IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA Case No.: CR-04-487-PHX-ROS MOTION TO EXTEND TIME TO FILE PRETRIAL MOTIONS AND CONTINUE TRIAL (Ninth Request)

16 Court to extend the deadline for filing pretrial motions for approximately thirty (30) days 17 18 19 20 trial date for approximately thirty (30) days from the current date of October 4, 2005. The parties believe they have reached a non-trial disposition (plea agreement), and hope to from the current date of August 29, 2005. Defendant also requests that the Court continue the

21 have a change of plea proceeding scheduled shortly. 22 The undersigned attorney has discussed these issues with the defendant, and he is in full

23 agreement with the relief sought herein. 24 25 26 27 no objection to the requested continuance. It is expected that excludable delay under Title 18 U.S.C. Section 3161(h)(1)(F) may Assistant U.S. Attorney, Bill Solomon, has been contacted regarding this motion, and has

28 occur as a result of this motion or from an order based thereon. Case 2:04-cr-00487-ROS Document 125 Filed 09/07/2005 Page 1 of 2

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RESPECTFULLY SUBMITTED this 7th day of September, 2005 by MICHAEL J. BRESNEHAN, P.C.

s/ Michael J. Bresnehan Attorney for Defendant CERTIFICATE OF SERVICE I hereby certify that on September 7, 2005, 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: Bill Solomon, Esq. Assistant U.S. Attorney Two Renaissance Square 40 N. Central, Suite 1200 Phoenix, Arizona 85004-4408 I hereby certify that on September 7, 2005, I served the attached document by MAIL on the following, who are not registered participants of the CM/ECF System: Teddy Lee Lowe Defendant s/ Dawn Larsen

Case 2:04-cr-00487-ROS

Document 125

2 Filed 09/07/2005

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