SHARRATT v. MURTHA

Filing 47

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SHARRATT v. MURTHA Doc. 47 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 April 27, 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. On April 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 April 27, 2009. Respectfully submitted, s/ W. Penn Hackney W. Penn Hackney, Assistant Federal Public Defender Attorney I.D. No. 29671 2

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