AGREED MOTION TO EXTEND TIME FOR FILING PRE-TRIAL MOTIONS - Page 1

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

UNITED STATES OF AMERICA §

V. § CRIMINAL NO. 3:05-CR-332-G

Judge Fish

KENNETH REVEN MCCLAIN §

MOTION TO EXTEND TIME FOR FILING PRE-TRIAL MOTIONS

TO THE HONORABLE UNITED STATES DISTRICT JUDGE:

NOW COMES the Defendant, KENNETH REVEN MCCLAIN, by and through undersigned

counsel and moves this Honorable Court to extend the date for filing Pre-Trial Motions from April 7,

2006, to April 14, 2006. In support of said motion, the Defendant would show unto the Court as

follows:

I.

A plea offer has been extended to the Defendant and the deadline to accept the plea offer is

April 14, 2006. Therefore, Defendant would request that the Pre-Trial Motions be due on the date

the plea offer expires, in the event the plea offer is not accepted by the Defendant.

WHEREFORE, PREMISES CONSIDERED, the Defendant respectfully requests this

Honorable Court to grant this Motion for Extension of Time for Filing Pre-Trial Motions to April 14,

2006.

Case 3:05-cr-00332-G Document 38 Filed 04/05/2006 Page 1 of 3
AGREED MOTION TO EXTEND TIME FOR FILING PRE-TRIAL MOTIONS - Page 2

Respectfully submitted,

LAW OFFICE OF JAMES P. WHALEN, P.C.

__________s/James P. Whalen__________________

JAMES P. WHALEN

TEXAS BAR CARD NO. 00794837

5700 W. Plano Parkway, Suite 1000

 Plano, Texas 75093

Telephone: (214) 368-2560

Facsimile: (972) 381-2781

COUNSEL FOR DEFENDANT

KENNETH REVEN MCCLAIM

CERTIFICATE OF CONFERENCE

This is to certify that undersigned counsel was able to confer with Chad E. Meacham, the

Assistant United States Attorney in charge of this case and he does not oppose the motion.

SIGNED this the 5th day of April, 2006.

__________s/James P. Whalen__________________

JAMES P. WHALEN

Case 3:05-cr-00332-G Document 38 Filed 04/05/2006 Page 2 of 3
AGREED MOTION TO EXTEND TIME FOR FILING PRE-TRIAL MOTIONS - Page 3

CERTIFICATE OF SERVICE

This is to certify that a true and correct copy of the foregoing motion was delivered to Chad

E. Meacham, Esq., the Assistant United States Attorney in charge of this case, 1100 Commerce

Street, Third Floor Dallas, Texas 75242, on this the 5th day of April, 2006.

__________s/James P. Whalen__________________

JAMES P. WHALEN

Case 3:05-cr-00332-G Document 38 Filed 04/05/2006 Page 3 of 3
ORDER- Motion to Extend Time for Filing Objections to the Presentence Report Page 1

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

UNITED STATES OF AMERICA §

V. § CRIMINAL NO. 3:05-CR-332-G

Judge Fish

KENNETH REVEN MCCLAIN §

ORDER

 ON THIS DAY came on to be heard Defendant's Motion to Extend Time for Filing PreTrial Motions; and after having considered the pleadings and arguments of counsel, the Court is

of the opinion that said motion should be and the same is hereby in all respects GRANTED and

Pre-Trial Motions are due on or before April 14, 2006.

SIGNED THIS THE _____ day of _________________, 2006.

____________________________________

UNITED STATES DISTRICT JUDGE

ORDER± Page Solo

Case 3:05-cr-00332-G Document 38-2 Filed 04/05/2006 Page 1 of 1