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JOHN S. LEONARDOUnited States AttorneyDistrict of Arizona
KATHY J. LEMKEAssistant U.S. AttorneyArizona State Bar No. 018468Two Renaissance Square40 N. Central Avenue, Suite 1200Phoenix, Arizona 85004-4408Telephone: (602) [email protected]
UNITED STATES DISTRICT COURT
DISTRICT OF ARIZONA
United States of America,
Plaintiff,
v.
Idan C. Greenberg
Defendant.
CR-10-1047–06-PHX-ROS
GOVERNMENT’S RESPONSE TODEFENDANT’S MOTION TO
CONTINUE
The United States, by and through undersigned counsel, does not object to the defendant’s
request to continue the August 7, 2012 trial date and extend the pre-trial motions for 60-days.
The United States disclosed approximately 90-pages of reports and attachments that
contain statements recently given to law enforcement officers by several co-defendants. These
co-defendants made statements about the defendant’s conduct and culpability in this case. A 60-
day continuance is reasonable to permit the defendant an opportunity to evaluate and effectively
prepare his case in light of the co-defendants’ statements.
Included in the disclosure were statements from an ancillary witness who was interviewed
about one of the co-defendant’s statements. The United States provided a copy of a separate,
and unrelated, investigative report for this ancillary witness. This separate investigative report
contained a tracing report for a firearm that the ancillary witness purchased and that was later
recovered in Mexico. This recovered firearm is not related to, nor is it relevant to, the
defendants, their conduct, or their charges.
Case 2:10-cr-01047-ROS Document 294 Filed 07/10/12 Page 1 of 2
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The United States requests this Court grant the defendant’s motion to continue for 60-
days as it serves the ends of justice in permitting the defendant the time necessary to effectively
prepare which outweighs the best interests of the public and the defendant in a speedy trial.
Respectfully submitted this 10th day of July, 2012.
JOHN S. LEONARDOUnited States AttorneyDistrict of Arizona
/s/Kathy J. Lemke
KATHY J. LEMKEAssistant U.S. Attorney
CERTIFICATE OF SERVICE
I hereby certify that on July 10, 2012, I electronically transmitted the attached document to the Clerk'sOffice using the CM/ECF System for filing and transmittal of a Notice of Electronic Filing to the followingCM/ECF registrants:
Gregory Anthony Bartolomei (CLARK) Joseph R. Conte (GOLDSTEIN) William Foreman (KALISH) Michael Smith (KALISH) Frederick Richard Petti (ARNBERGER) Robert E. Sanders (RODMAN) Loyd C. Tate (GREENBERG)
/s/ Kathy J. Lemke KATHY J. LEMKEAssistant United States Attorney
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Case 2:10-cr-01047-ROS Document 294 Filed 07/10/12 Page 2 of 2
