Opinion
No. 3:12-00175
10-16-2012
UNITED STATES OF AMERICA v. ROBERT H. JOHNSON
CARYLL S. ALPERT (BPR#017021) Assistant Federal Public Defender Attorney for Robert H. Johnson
JUDGE TRAUGER
MOTION TO EXTEND TIME FOR FILING PRETRIAL MOTIONS
Through counsel, defendant Robert H. Johnson moves to extend the time for filing pretrial motions. This matter currently is set for trial on October 30, 2012.
In support of this motion, defense counsel would show the following: This matter involves a search of Mr. Johnson's home which revealed apparently incriminating items. Defense counsel has requested but not yet received critical discovery related to the search of the home. The government has advised that this requested discovery is forthcoming. Defense counsel cannot determine whether pretrial motions are appropriate or necessary until defense counsel reviews the requested documents and discusses the matter thoroughly with Mr. Johnson. For these reasons, the defendant moves to extend the deadline for filing a pretrial motions. It is likely that the defendant will also need to request a postponement of the October 30 trial date in order to complete the research and investigation needed, but counsel will file that motion under separate cover.
Respectfully submitted,
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CARYLL S. ALPERT (BPR#017021)
Assistant Federal Public Defender
Attorney for Robert H. Johnson