Katherine Shea, assistant federal public defender, filed the motion Wednesday.

Shea requests in the motion to extend the pretrial motions deadline three months until November 15 and continue the arraignment for three months until the December term of court.

“Although defense counsel have diligently waded through discovery since mid-June, defense counsel require additional time to complete the review of and synthesize discovery,” the motion says. “Additionally, twelve of our fourteen clients have been detained all across the district, and even outside the district in Piedmont Regional Jail. With the protective order in place defense counsel or counsel staff must review the bulk of the discovery, audio and video, with their clients in locations hours away.”

Shea writes in the motion, “Reviewing this audio and video discovery with our clients in detention centers takes time. Especially because of the enormous penalties associated with the charges in the indictment, defense counsel have a duty to thoroughly research potential pretrial motions and continue to confer extensively with clients about the course of action to take in this case.”

A three month-extension of the pretrial motions deadline and a three-month continuance of the arraignment, Shea argues in the motion, “is necessary for defense counsel to satisfy our duties to our clients to provide adequate representation.

“The government has indicated that it opposes any continuance or extension longer than thirty days. The defense makes this request in good faith and not for purposes of delay. Neither the government nor the defendants would be prejudiced by the continuance and extension sought in this motion. The ends of justice served by this motion outweigh the interests of the public in a speedy trial.”

In stating the background of the case, Shea also notes the staggering amount of evidence collected in the investigation, which culminated on April 22 through a 54-count indictment against the 15 defendants.

Shea calls Operation Rockfish a government reverse sting running for 18 months and leading to charges of narcotics trafficking, using a firearm in furtherance of drug trafficking, money laundering, and bribery.

All defendants face significant mandatory minimum sentences in the indictment, ranging from ten years to sixty-five years.

The original scheduling order set the pretrial motions deadline for August 15; a response deadline of August 30 and arraignment on September 9.

“Although the court ordered the parties to conduct a pretrial conference no later than May 22, the government first attempted to make available to defense counsel hard drives with discovery on June 2. However, because many of the defense counsel could not access any discovery off the first hard drive, the government recalled these initial hard drives and issued new hard drives on June 9.”

The hard drives contain 5,385 encrypted files in 599 folders totaling 273 gigabytes of data, Shea noted. “To give the court an idea of how much discovery the government has provided, one defense counsel has had a summer extern exclusively review discovery since receiving the second hard drive from the government for 40-50 hours per week. As of today, she still has not completed her review.”