MOTION TO CONTINUE TRIAL



COMES NOW the defendant, *, through his counsel, and hereby moves to continue the trial of this cause until the next term of court, based on the following grounds:

1. The undersigned has been unable to complete his investigation in preparation for the trial of this case because of extensive involvement in the post-conviction hearings in the case of United States v. MacAllister, Case No. 94-255(S2)-Cr-J10, including full days on September 5, 6, 13, and also scheduled for October 3, 1995.

2. The undersigned has recently learned that there were other suspects in this bombing and needs to pursue this avenue of defense.

3. The undersigned has been otherwise busy with a two day proffer in the case of *and the district wide Federal Defenders conference in Longboat Key.

4. The undersigned has contacted Steve Kunz, Ass't. U. S. Attorney, who is prosecuting this case and he is not opposed to a one term continuance, but is opposed to further delay.

5. The defendant is prepared to waive his speedy trial rights through November, 1995.

























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