`
`UNITED STATES DISTRICT COURT
`DISTRICT OF SOUTH DAKOTA
`WESTERN DIVISION
`
`CIV. 14-50063
`
`MOTION FOR CONTINUANCE OF
`DEADLINES
`
`)))))))))
`
`UNITED STATES OF AMERICA,
`
`Plaintiff,
`
` vs.
`
`ALEXANDROS THYMARAS,
`
`Defendant.
`
`Defendant, through counsel, moves for a continuance of certain deadlines in this case.
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`Presently the deadline for Defendant to file suppression/voluntariness motions and to issue
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`subpoenas for suppression hearings is February 24, 2015. (Docket 46). Defendant moves for a
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`two week continuance for these two deadlines. Undersigned counsel understands that Assistant
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`United States Attorney, Sarah Collins, consents to this request. Undersigned counsel represents
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`that this Motion is not made for unreasonable delay or an unreasonable purpose. A letter from
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`pro hac vice counsel, Brian L. Gardner, is attached to this Motion and incorporated by this
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`reference.
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`Dated this 24th day of February 2015.
`
`GUNDERSON, PALMER, NELSON
`& ASHMORE, LLP
`
`By___/s/Jeffrey R. Connolly_______________
`Jeffrey R. Connolly
`P.O. Box 8045
`506 Sixth Street
`Rapid City, SD 57709-8045
`(605) 342-1078
`jconnolly@gpnalaw.com