Opinion
No. 3:12-00188
11-15-2012
UNITED STATES OF AMERICA, Plaintiff, v. DEBBIE FOUST, Defendant.
CHIEF JUDGE HAYNES
MOTION TO CONTINUE TRIAL AND TO
EXTEND PRETRIAL FILING DEADLINES
COMES NOW the Defendant, Debbie Foust, by and through her undersigned counsel, and respectfully requests that this Honorable Court enter an Order continuing the trial of this case from December 4, 2012. to a later date and resetting all pretrial and plea deadlines in accordance with the new trial date. For the reasons stated below, a resettingof the trial will give the parties adequate time to determine if the matter can be resolvedwithout the need of a trial and for defense counsel to fulfill his obligations for Defendant Foust.
1. On October 5, 2012, the Court entered an Order scheduling this case for trial. (Docket Entry no. 8, Order). The scheduling Order provided for a plea deadline of November 16, 2012. This is the first request to continue the trial.
2. The Government has timely provided discovery. The Assistant U.S. Attorney has answered questions posed by counsel for Defendant Foust pertaining to parts of the discovery production.
3. An important function of defense counsel's obligations is to explore disposition