ONG red -felmy el” & SUPERIOR COURT FOR THE DISTRICT OF COLUMBIA. Criminal Division -- Felony Branch Ha ? 21 UNITED STATES OF AMERICA mi N23 P 2 Criminal Case No. 2009 CF1,9230 ve Hon. Gerald Fisher ace Sentencing Date: February 11,2011 INGMAR GUANDIQUE MOTION FOR EXTENSION OF TIME WITHIN WHICH TO FILE MOTION FOR NEW TRIAL Ingmar Guandique, through undersigned counsel, respectfully moves this Honorable Court, pursuant to Superior Court Criminal Rule 33, for an extension of time within which to file his motion for a new trial, presently due on November 29, 2010, to the sentencing date in this case, As required by Rule 33, undersigned counsel further requests that prior to November 29, 2010, the Court enter an Order granting the extension of time to the sentencing date in this case. ‘As grounds for this Motion, undersigned counsel states: 1) On November 22, , after a jury trial, Mr. Guandique was convicted of first-degree- degree murder. Under Rule 33, the deadline for the filing of a motion for new trial would be November 29, 2010, seven days after the verdict was retumed. 2) Due to the press of other business, the need to conduct further investigation, and the need for other steps preliminary to the filing of a motion for new trial, undersigned counsel will not be able to file a motion for new trial by November 29, 2010. 3) Given that Mr. Guandique remains incarcerated and given the length of the sentence he is facing, no prejudice should accrue by extending the deadline for the filing of the new trial motion in this case. WHEREFORE for the foregoing reasons, those which may appear in supplementalpleadings, which Mr. Guandique explicitly reserves the right to file, and any others this Court deems just and proper, Ingmar Guandique, through counsel, respectfully requests that this Motion be granted and that the November 29, 2010, deadline for the filing of the new trial motion be extended until the time of Mr. Guandique’s sentencing. Dated: November 22, 2010 Respectfully submitted, Mauls Hees Isg y v0, So | Maria Hawilo (D.C. Bar. No. 490-084) ia Sonenberg (D.C. Bar No. 3 On Behalf of Ingmar Guandique (On Behalf of Ingmar Guandique Public Defender Service Public Defender Service 633 Indiana Avenue, N.W. 633 Indiana Avenue, NW Washington, D.C. 20004 Washington, DC 20004 (202) 824-2546 (202) 824-2308 CERTIFICATE OF SERVICE I hereby certify that @ copy of the foregoing has been delivered, by hand and telecopier at (202) 305-1577, on this 30th day of November, 2010, to: Femando Campoamor Sanchez. and Amanda Haines Office of the United States Attomey 555 Fourth Street, N.W. Washington, D.C. 20530 Wy fy G il Santha SonenbergSUPERIOR COURT FOR THE DISTRICT OF COLUMBIA Criminal Division -- Felony Branch UNITED STATES OF AMERICA. Criminal Case No. 2009 CF1 9230 v. : Hon. Gerald Fisher Sentencing Date: February 11, 2011 INGMAR GUANDIQUE, ORDER This matter having come before the Court on Mr. Guandique’s Motion for Extension of ‘Time Within Which To File Motion For New Trial, and good cause having been shown, it is this day of November, 2010, HEREBY ORDERED that the motion is GRANTED, and ‘a motion for new trial may be filed up unti the sentencing in this matter. Copies To Maria Hawilo and Santha Sonenberg Gerald Fisher Public Defender Service Associate Judge 633 Indiana Avenue, N.W. Superior Court for the District of Columbia Washington, D.C. 20004 Fernando Campoamor Sanchez and Amanda Haines Office of the United States Attorney 555 Fourth Street, N.W. Washington, D.C. 20530