Opinion
No. 3:12-00041
11-16-2012
UNITED STATES OF AMERICA v. CHARLES GLENN, IV
Motion GRANTED conditioned upon the timely filing of a waiver of speedy trial.
Judge
MOTION TO CONTINUE TRIAL
COMES NOW the Defendant, by and through counsel, and respectfully requests the Court to continue the trial currently set for November 20, 2012. The United Stated Attorney's Office, through Philip Wehby, has been contacted and does not object to this request.
In support of a continuance, the Defendant asserts that (1) he needs additional time to engage in plea negotiations given the results of the recent suppression hearing and; (2) counsel needs additional time to prepare for trial, particularly to properly investigate the Confidential Informant once his identity is disclosed.
The Defendant has agreed to waive speedy trial. A signed speedy trial waiver will be submitted.
Accordingly, for the reasons stated, the Defendant requests the trial be continued and a new trial date be set.
Respectfully submitted,
_______________
James E. Mackler (BPR #024855)
BONE MCALLESTER NORTON
511 Union Street, Suite 1600
Nashville, TN 37219
(615) 238-6312 (phone)
(615) 248-4668 (facsimile)
Email: jmackler@bonelaw.com