Pretrial Conference to request continuance of trial [Patrick Fox; Bernie Wolfe (BCPS)]

Mr. Wolfe:

As discussed briefly in court on July 26, 2019, I respectfully request you schedule a pretrial conference in the referenced matter, so I may apply to the court to postpone the start of the trial in order to allow more time for me to obtain evidence which I believe to be critical to my defense.

The evidence I seek to obtain is as follows:

1. The DNA of Ricky Riess's parents. This has already been discussed at length so I don't believe anything more needs to be said here. I have, to date, received no response from either party on my attempts to communicate with them in this matter.
2. CBSA's video footage of me at the border on March 15, 2019, specifically my movement from their building north of the border to the actual, physical border.
3. Testimony of a CBSA officer, preferably one or both of the ones I interacted with on March 15, 2019 at the Peace Arch border crossing. I think it should be pretty obvious what I intend to question her on.
4. CBP Officer Geoffrey Obrist. I know he is on your witness list but I suspect you're going to remove him from your list when you realize some of his testimony on cross is likely to be very helpful to my purposes. Therefore, this is my formal request for you to produce him as a witness.

With respect to the dates I would like to have the PTC: I am open to any of the following: August 1, 2, 5, 6, 7, 8, 9, or 12. In other words, any day between now and the start of trial – I really don't care.

Not surprisingly, CBSA is being incredibly uncooperative with me. I am hoping you or the RCMP will have more success with them.

Please let me know if you have any questions.

Thank you.