Saleem Khan told Magistrate Vanitha Armu that “the accused has faced extensive prejudice by the delay in prosecution”.
He said Mdunge had become aware of the investigations against him when he was approached two years ago.
Prosecutor Barend Groen told the court the State wanted an adjournment to finalise an audit.
Mdunge faces a charge of fraud relating to allegations that he had used a fake matric certificate 25 years ago when he joined the police in 1987. He resigned in September, when the allegation surfaced.
He was arrested on October 8 when he also appeared in court.
At that appearance Groen told the court the State was still trying to determine the value of the alleged fraud.
A colonel earns between R500,000 and R600,000 a year.
Groen was quoted in The Mercury newspaper at the time as saying that it could amount to millions as Mdunge should never have been employed in the first place.
The calculation would also have to take into account allowances, housing subsidies, and other benefits.
However, Khan argued on Thursday that there was no reason why the court could not set a trial date with sufficient time for the State to complete the audit.
Armu granted the State a final adjournment until November 21 to finalise the audit, when it was expected that a trial date would be set.