SHARRATT v. MURTHA

Filing 45

SHARRATT v. MURTHA

Doc. 45

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF PENNSYLVANIA UNITED STATES OF AMERICA v. TONY MARCELLUS FREDERICKSON ) ) ) ) )

Criminal No. 07-368

MOTION TO EXTEND THE TIME FOR FILING PRETRIAL MOTIONS AND NOW comes the defendant, Tony Marcellus Frederickson, by his attorney, W. Penn Hackney, Assistant Federal Public Defender, and respectfully moves this Honorable Court for an extension of time of 60 days in which to file pretrial motions. states: In support thereof, counsel

1.

The defendant, Tony Marcellus Frederickson, was

arraigned on an indictment alleging violations of Title 18, U.S.C. §§ 922(g)(1), 922(n), and 922(a)(6). Pursuant to

Local Rule 12.1, certain pretrial motions are due on February 24, 2009.

2.

Additional time is needed to complete counsel's

investigation of the facts and law before informed decisions can be made concerning the filing of pretrial motions.

Dockets.Justia.com

3.

In a telephone conversation with the office of defense

counsel on February 24, 2009, Assistant United States Attorney Ross Lenhardt stated that he does not object to the granting of this motion.

WHEREFORE, your defendant, Tony Marcellus Frederickson, respectfully moves this Honorable Court to extend the time for filing pretrial motions for 60 days from February 24, 2009. Respectfully submitted,

s/ W. Penn Hackney W. Penn Hackney, Assistant Federal Public Defender Attorney I.D. No. 29671

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