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

Case 1:07-cr-00158-GMS

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Filed 02/29/2008

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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 three 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 3, 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 an additional extension from March 3,

Case 1:07-cr-00158-GMS

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2008 until March 28, 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 placed a call to Mr. Keith Rosen in the U.S. Attorney's Office

on February 27, 2008, but has not yet discussed this Motion with Mr. Rosen. 5. Counsel has also filed this date a Motion to permit him to employ his own translator,

so the he may obtain a translation of the recordings and file his motions thereafter without having to seek further continuances. WHEREFORE, Defendant requests that this Court extend the time for the filing of his pretrial Motions from March 3, 2008 to March 28, 2008. BIGGS AND BATTAGLIA

DATED: 2/29/2008

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

Case 1:07-cr-00158-GMS

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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

ORDER Upon Motion to Extend the Deadline for Defendant Julio Gonzalez to File Pretrial Motions and it appearing that there is good cause therefore, the Court hereby extends the time for filing pretrial Motions from March 3, 2008 to March 28, 2008. IT IS SO ORDERED

Dated: _______________

J. _______________________________

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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

CERTIFICATE OF SERVICE I hereby certify that on February 29, 2008, I electronically filed the Motion by Defendant to Extend the Deadline for Defendant to File Pre-trial Motions and Order with the Clerk of Court using CM/ECF, which will send notification of such filing(s) to the following: Keith Rosen U.S. Department of Justice Nemours Building, 1007 Orange Street Suite 7100 Wilmington, DE 19801

BIGGS AND BATTAGLIA

DATED: 2/29/2008

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