Free Motion for Extension of Time to File - District Court of Delaware - Delaware

Case 1:07-cr-00158-GMS

Document 24

Filed 03/28/2008

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE STATE OF DELAWARE UNITED STATES OF AMERICA, Plaintiff, v. JULIO GONZALEZ, Defendant. ) ) ) ) ) ) ) ) )

Cr.A. No.: 07-158 UNA

MOTION TO EXTEND THE DEADLINE FOR DEFENDANT TO FILE PRETRIAL MOTIONS Defendant Julio Gonzalez, by and through his attorneys hereby moves that this Court enter the attached Order providing additional time for him to file his pre-trial Motions and in support thereof, states as follows: 1. Defendant entered a plea of not guilty to his indictment on November 29, 2007. At

that same time, he was given until December 29, 2007 to file his pre-trial Motions. 2. Defendant filed a timely request for discovery on December 10, 2007 and has received

documents from the U.S. Attorney's Office in response to that Motion. In addition to documentary evidence, there are also recordings, which are in Spanish, and which have not yet been translated into English. Defendant has previously requested four continuances while awaiting the English translations of the recordings and this Court granted his last motion to extend the date for him to file his pre-trial Motions to March 28, 2008. 3. These translations, which are essential for the preparation of Defendant's case, have

yet to be prepared and, for that reason, Defendant requests one more extension from

Case 1:07-cr-00158-GMS

Document 24

Filed 03/28/2008

Page 2 of 2

March 28, 2008 until April 18, 2008 to file his pre-trial Motions. Defendant's attorney needs the English translations, as a starting point, in order to understand and evaluate this case. 4. Defendant's counsel advised Mr. Keith Rosen in the U.S. Attorney's Office that he

would be filing this motion and Mr. Rosen did not object. 5. Counsel previously filed a Motion to permit him to employ his own translator,

which was granted on March 19, 2008. WHEREFORE, Defendant requests that this Court extend the time for the filing of his pretrial Motions from March 28, 2008 to April 18, 2008.

BIGGS AND BATTAGLIA

DATED: 3/28/2008

By: /s/ Robert D. Goldberg Robert D. Goldberg (ID # 631) Biggs and Battaglia 921 North Orange Street P.O. Box 1489 Wilmington, DE 19899 (302) 655-9677 Attorney for Defendant Julio Gonzalez