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UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF TEXAS

AUSTIN DIVISION

UNITED STATES OF AMERICA §

§

v. § NO: AU:20-CR-00047(4)-RP

 §

(4) RICARDO ALBERTO HERNANDEZ §

MOTION TO EXTEND FILING DEADLINES AND TRIAL DATE

Defendant, Mr. Ricardo Alberto Hernandez, through undersigned Counsel, requests the 

Court extend the filing deadlines and the trial date. He would show as follows: 

1. On July 29, 2021, the Court set the following deadlines and Jury trial dates (docket 

#416):

Pretrial motions to be filed by 8/10/2021;

Responses to pretrial motions to be filed by 8/24/2021; 

Plea Agreement due by 8/24/2021;

All Pending Pretrial Matters and Docket Call set for 9/12/2021;

Jury Selection and Trial set for 9/13/2021. 

2. The Court appointed Richard Cofer to represent Mr. Alberto Hernandez on August 

10, 2021.

3. Counsel for Mr. Alberto Hernandez requests additional time to review discovery; 

file pretrial motions; and discuss plea negotiations with the government.

4. Mr. Alberto Hernandez requests that the Court:

a. Designate this case as complex; and 

Case 1:20-cr-00047-RP Document 455 Filed 08/12/21 Page 1 of 3
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b. Extend the deadlines and trial date at least ninety (90) days so that counsel 

can prepare for trial.

5. The Court may grant an extension for good cause under Rule 45(b) of the Federal 

Rules of Criminal Procedure. 

Respectfully submitted this 11th day of August, 2021.

COFER & CONNELLY, PLLC

1002 West Avenue

Austin, Texas 78701

512-200-3801 telephone

512-727-5568 facsimile

By: /s/ Richard L. Cofer

Richard Lyn Cofer

Texas State Bar No. 24065059

rick@coferconnelly.com

Counsel for Ricardo Alberto Hernandez

CERTIFICATE OF SERVICE

I certify that on August 12, 2021, a true and correct copy of the above document was 

served on the United States Attorney’s Office in Austin, Texas, through the Court’s electronic 

filing system. 

/s/ Richard L. Cofer

Richard Lyn Cofer

Case 1:20-cr-00047-RP Document 455 Filed 08/12/21 Page 2 of 3
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UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF TEXAS

AUSTIN DIVISION

UNITED STATES OF AMERICA §

§

v. § NO: AU:20-CR-00047(4)-RP

 §

(4) RICARDO ALBERTO HERNANDEZ §

ORDER ON DEFENDANT’S MOTION TO EXTEND

PRETRIAL MOTIONS DEADLINE AND TRIAL DATE

Came on for consideration this day Defendant’s Motion to Extend Pretrial Motions 

Deadline and Trial Date filed August 12, 2021. Having considered the grounds for said Motion, 

the Court is of the opinion that Defendant should be given an extension of the deadline for filing 

pretrial motions, the motions hearing and docket call, and the jury trial in this case.

IT IS THEREFORE ORDERED that the deadline for filing pretrial motions is extended 

to __________ o’clock ___.m. on the _________ day of _____________________, 20__.

IT IS THEREFORE ORDERED that the motions hearing and docket call is extended to

__________ o’clock ___.m. on the _________ day of _____________________, 20__.

IT IS THEREFORE ORDERED that the jury trial in this case is extended to __________

o’clock ___.m. on the _________ day of _____________________, 20__.

SIGNED AND ENTERED this ______ day of ______________________, 2021. 

____________________________________

UNITED STATES DISTRICT JUDGE

Case 1:20-cr-00047-RP Document 455 Filed 08/12/21 Page 3 of 3