Documentos de Académico
Documentos de Profesional
Documentos de Cultura
have not been produced, and the audits are central to the issues of cheating that are alleged in this
case. Defense counsel must obtain, possibly by subpoena, the remaining audits, determine which
are relevant and helpful to the defense, and then send copies to the Government. All of this takes
a considerable amount of time. Defendants believe that we are entitled to such audits and the
audits are in the control of the Government.
Additional time is needed in this case for trial preparation and for negotiation. The
Government has been investigating this case for over seven years and Defendants have had this
case for less than one year. Defendants have been diligently going over discovery and are
actively seeking relevant information that may not be in the discovery provided by the
Government. This case involves years of conduct and involves matters that happened over ten
years ago. The case has already been designated as complex, and additional time is necessary for
counsel to fulfill their constitutional duties under the Sixth Amendment. All remaining
defendants are in agreement that additional time for defense preparation is necessary to protect
Defendants due process rights and to insure that all of the defendants receive a fair trial schedule
that does not inherently favor the Government.
II.
In addition to the foregoing, this case will involve over fifty witnesses, many of whom
live outside of the El Paso area. Coordination of witnesses will be logistically difficult if this trial
should occur during the school year. For this reason, Defendants respectfully request that this
case be scheduled during the summer months when school is not in session. Additional time in
this case is thus needed for trial preparation and negotiation.
III.
This motion is not made for the purpose of delay, but in the interests of justice. For these
reasons, Defendants request that the Court grant this motion for continuance and reschedule the
jury selection and trial setting until summer 2017.
Respectfully submitted,
/s/ Elizabeth Rogers
ELIZABETH ROGERS
State Bar No. 17165400
509 N. 6th Street
Alpine, Texas 79830
Phone: (432) 538-7070
Cell: (432) 386-6567
lizrogersalpine@yahoo.com
ATTORNEY FOR DEFENDANT TANNER
Thomas W. Mills, Jr.
THOMAS W. MILLS, JR.
MILLS & WILLIAMS, L.L.P.
5910 N. Central Expressway, Suite 980
Dallas, Texas 75206-5141
Phone (214) 265-9265
Fax (214) 363-3167
tmills@millsandwilliams.com
ATTORNEY FOR DEFENDANT TANNER
Robert J. Perez
Robert J. Perez
rjperezlaw@yahoo.com
ATTORNEY FOR DEFENDANT ANDERSON
Luis E. Islas
Luis E. Islas
luiseislas48@hotmail.com
ATTORNEY FOR DEFENDANT TEGMEYER
DATE: ________________________
____________________________
DAVID BRIONES
UNITED STATES DISTRICT
COURT JUDGE