Opinion
CRIM. CASE NO. 1:12-CR-00001
12-04-2012
JUDGE TRAUGER
MOTION FOR EXTENSION OF TIME TO FILE PRE-TRIAL MOTIONS
Comes now the Defendant, through undersigned counsel, and moves this Honorable Court for an extension of time within which to file pre-trial motions. As grounds therefore, the Defendant would show as follows:
1. Pre-trial motions are currently due on November 30, 2011. [Doc. No. 73]
2. The Defendant has a current trial date of January 15, 2013. [Doc. No. 93]
3. The Defendant has received the discovery within the last week in the superceding indictment, but has not had adequate opportunity to review it or confer with the Defendant regarding the case, the discovery or other matters.
4. At this point, in addition to determining what, if any pre-trial motions are necessary, the Defendant needs additional time to investigate the case, review all the discovery materials, consult further with the Defendant and engage the government in settlement negotiations.
Counsel has a conflict with the current trial schedule and will be filing an appropriate motion as soon as counsel has had opportunity to speak with Mr. Hampton on December 6, 2012.