Anda di halaman 1dari 4

Case 2:10-cr-01047-ROS Document 275 Filed 06/21/12 Page 1 of 3

1 2 3 4 5 6 7 8 9
7272 East Indian School Road, Ste. 203 SCOTTSDALE, ARIZONA 85251 (480) 941-2700

William Foreman, P.C. (010617) 7272 East Indian School Road Suite 203 Scottsdale, Arizona 85251 (480) 941-2700 FAX: (480) 481-9021 william.foreman@azbar.org Attorney for Defendant __________ Michael Smith (011105) Gonzalez and Smith, P.C. 2340 W. Ray Road, Suite 1 Chandler, Arizona 85224 Telephone: (480) 491-9750 FAX: (480) 491-9260 Email: gonzalezandsmith@aol.com IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA United States of America, Plaintiff, vs. Lorren Kalish, Defendant. Defendant, Lorren Kalish, through undersigned counsel, respectfully requests this Court to extend the time for filing pretrial motions from Friday, June 22, 2012 until Friday, July 20, 2012. The basis for this request is that on June 18, 2012 the Government disclosed 14 pages of discovery, a narrative report that discusses the content of a meeting conducted by and between a co-defendant, his counsel and the Government. As a direct consequence of this recent disclosure, Mr. Kalish needs additional time to assess the information contained therein. No. CR-10-1047-PHX-ROS MOTION TO EXTEND TIME FOR FILING PRETRIAL MOTIONS (Fourth Request)

WILLIAM F OREMAN, P. C.

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27

Case 2:10-cr-01047-ROS Document 275 Filed 06/21/12 Page 2 of 3

1 2 3 4 5 6 7 8 9
7272 East Indian School Road, Ste. 203 SCOTTSDALE, ARIZONA 85251 (480) 941-2700

Also, on June 21, 2012, Mr. Kalish advised counsel undersigned that he will be required to undergo a surgical procedure on his heart now scheduled for July 2, 2012. As a consequence, he will be unavailable to consult with counsel undersigned regarding potential pretrial motion issues until approximately July 9, 2012. Counsel for the Government is currently out-of-state, so undersigned counsel was unable to communicate with her about this requested continuance. Undersigned counsel expects that excludable delay under Title 18 U.S.C. Section 3161(h) (7) (A) may occur as a result of this motion or from an order based thereon. DATED this 21st day of June, 2012. William Foreman William Foreman, P.C. 7272 East Indian School Road, Suite 203 Scottsdale, Arizona 85251 And Michael Smith Gonzalez and Smith, P.C. 2340 W. Ray Road, Suite 1 Chandler, Arizona 85224 By s/William Foreman William Foreman Attorneys for Defendant Lorren Kalish

WILLIAM F OREMAN, P. C.

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27

Case 2:10-cr-01047-ROS Document 275 Filed 06/21/12 Page 3 of 3

1 2 3 4 5 6 7 8 9
7272 East Indian School Road, Ste. 203 SCOTTSDALE, ARIZONA 85251 (480) 941-2700

CERTIFICATE OF SERVICE I hereby certify that on June 21, 2012, I electronically transmitted the attached document entitled Motion to Extend Time for Filing Pretrial Motions (Fourth Request) to the Clerks Office using the CM/ECF System for filing and transmittal of Notice of Electronic Filing to the following CM/ECF registrants: Kathy Jo Lemke Assistant U.S. Attorney Gregory Bartolomei, Esq. Attorney for George Clark, III Robert Sanders, Esq Attorney for Randolph Rodman Joe Conti, Esq. Attorney for Hal Goldstein Fred Petti, Esq. Attorney for James Arnberger Loyd Tate, Esq. Attorney for Idan Greenberg s/Rebecca Allen kathy.lemke@usdoj.gov gregory_bartolomei@fd.org gunlaw@triad.rr.com dcgunlaw@gmail.com fpetti@aztraillaw.com ltate@btlayers.com

WILLIAM F OREMAN, P. C.

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27

Case 2:10-cr-01047-ROS Document 275-1 Filed 06/21/12 Page 1 of 1

1 2 3 4 5 6 7 8 9
7272 East Indian School Road, Ste. 203 SCOTTSDALE, ARIZONA 85251 (480) 941-2700

IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA United States of America, Plaintiff, vs. Lorren Kalish, Defendant.
Upon motion of the defendant, and good cause appearing therefore, IT IS HEREBY ORDERED GRANTING the defendants Motion to Extend Time for Filing Pretrial Motions. This Court specifically finds that the ends of justice served by granting a continuance outweigh the best interest of the public and the defendant. This finding is based upon the Courts conclusion that the failure to grant such a continuance could deny the defendant the reasonable time necessary for effective preparation, taking into account the exercise of due diligence. 18 U.S.C. Section 3161(h)(7)(A). IT IS THEREFORE ORDERED continuing the date for filing pretrial motions from June 22, 2012 to July 20, 2012.

No. CR-10-1047-PHX-ROS I. II. ORDER (Fourth Request)

WILLIAM F OREMAN, P. C.

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27

DATED this ____ day of __________________, 2012.

_____________________________________ THE HONORABLE ROSLYN O. SILVER United States District Court Judge