Opinion
Case No. 3:12-00220
01-23-2013
UNITED STATES OF AMERICA v. PAUL EICHEL
Judge Haynes
MOTION TO CONTINUE TRIAL DATE
COMES NOW the Defendant, Paul Eichel, by and through his undersigned counsel, and respectfully requests that this Honorable Court enter an order continuing the trial of the above-captioned case from Tuesday, February l2, 2013 at 9:00 a.m. to a later date convenient to the Court and counsel, In support hereof, Defendant states as follows:
1. The trial of this case is currently scheduled for Tuesday, February 12, 2013 at 9:00 a.m. (Docket Entry 13). This is the first setting for trial. Mr. Eichel is on bond.
2. Consistent with this Court's Order setting the case for trial, undersigned counsel has contemporaneously filed a supporting affidavit stating the reasons for the continuance. (Docket Entry16). The Order also requires counsel to suggest "proposed alternative trial dates and other pretrial deadlines." Id. Given counsel's current trial schedule, he realistically would not be available to try the case until September 2013. A reasonable pretrial motion deadline would be on or before the close of business on Friday, May 3, 2013.
3. Assistant United States Attorney Brent A. Hannafan has authorized undersigned counsel to report that the government does not object to the Defendant's request to continue the 2/12/13 trial date.
4. Defendant Eichel will supplement this filing with an appropriate, executed Waiver