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

Case 1:07-cr-00158-GMS

Document 13

Filed 12/27/2007

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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

UNOPPOSED 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's attorney needs the English translations, as a starting point, in order to understand and evaluate the recordings. 3. Defendant's counsel has spoken with Mr. Keith Rosen in the U.S. Attorney's Office

and he advised that the Government does not oppose this Motion.

Case 1:07-cr-00158-GMS

Document 13

Filed 12/27/2007

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WHEREFORE, Defendant requests that this Court extend the time for the filing of his pretrial Motions from December 29, 2007 to January 21, 2008. BIGGS AND BATTAGLIA

DATED: 12/27/2007

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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Filed 12/27/2007

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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 and that such Motion is unopposed. The Court hereby extends the time for filing his pretrial Motions from December 29, 2007 to January 21, 2008. IT IS SO ORDERED

Dated: _______________

J. _______________________________