Free Motion for Stay - District Court of Colorado - Colorado

Case 1:00-cr-00531-WYD

Document 1962

Filed 10/13/2006

Page 1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Criminal Case No. 00-cr-00531-WYD UNITED STATES OF AMERICA, Plaintiff, v. RUDY CABRERA SABLAN, et al. Defendant. ______________________________________________________________________________ UNOPPOSED MOTION FOR STAY ON FILING OF NON-EXPERT WITNESS LISTS AND EXHIBIT LISTS AS TO RUDY SABLAN (R-61) ______________________________________________________________________________ Rudy Sablan requests a stay on the filing of non-expert witness lists and exhibit lists as to his trial. In support of the stay requested, Mr. Sablan states as follows: 1. On June 7, 2005, the Court entered a scheduling order which requires the parties

to file non-expert witness lists and exhibit lists by October 13, 2006. At that time the Defendants were joined for trial. 2. The Court granted the Defendant's Motions for Severance on July 28, 2006

(Docket #1852). The trial of William Sablan is scheduled to proceed first, on January 22, 2006. No trial date has been set for Rudy Sablan. 3. Given the status of the proceedings against Rudy Sablan after severance, it would

be premature for either the government or Defendant Rudy Sablan to file witness and exhibit lists at this time. Those lists will undoubtedly be affected by the trial of co-Defendant William Sablan.

Case 1:00-cr-00531-WYD

Document 1962

Filed 10/13/2006

Page 2 of 3

4. this motion.

AUSA Brenda Taylor has authorized counsel to state that the government joins in

WHEREFORE, Defendant Rudy Sablan requests an order staying the filing of witness lists and exhibit lists for his trial until a trial date has been set. Respectfully submitted, s/ Forrest W. Lewis Forrest W. Lewis FORREST W. LEWIS, P.C. 1600 Broadway, Suite 1525 Denver, Colorado 80202 Telephone: (303) 830-2190 Facsimile: (303) 830-1466 E-mail: [email protected] Donald R. Knight KNIGHT & MOSES, LLC 7852 S. Elati Street, Suite 201 Littleton, Colorado 80120 Telephone: (303) 797-1645 Facsimile: (303) 798-3872 E-mail: [email protected] Attorneys for Defendant Rudy Sablan

Case 1:00-cr-00531-WYD

Document 1962

Filed 10/13/2006

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that the foregoing was UNOPPOSED MOTION FOR STAY ON FILING OF NON-EXPERT WITNESS LISTS AND EXHIBIT LISTS AS TO RUDY SABLAN (R-61) electronically filed with the Clerk of the Court using the CM/ECF system on this 13th day of October, 2006, which will send notification of such filing to the to the following e-mail addresses: Brenda Taylor [email protected] Philip Brimmer [email protected] Patrick J. Burke [email protected] Dean Neuwirth [email protected] Nathan D. Chambers [email protected] Susan L. Foreman [email protected]

s/Polly Ashley