Free Motion to Continue - District Court of Arizona - Arizona

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JON M. SANDS Federal Public Defender District of Arizona 850 West Adams, Suite 201 Phoenix, Arizona 85007 Telephone: (602) 382-2739 JEFFREY A. WILLIAMS, Bar Assoc. #012605 Asst. Federal Public Defender Attorney for Defendant [email protected] IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA United States of America, Plaintiff, -vsEric Miguel, Defendant. No. CR-04-1289-PHX-EHC MOTION TO CONTINUE TRIAL (4th Request)

Defendant, through undersigned counsel, respectfully moves that this court continue the trial date for a period of at least thirty (30) days from the current date of November 1, 2005. The reason is that counsel has recently engaged the services of Drs. Robert Bux and John Plunkett. Doctors Bux and Plunkett are both forensic pediatric pathologists and have indicated that they would need a brief time to prepare for trial, however, their work and trial schedules are suck that they could not be available to testify until the week of December 19, 2005, and are available for the entire month of January. Due to the nature of this case, counsel feels that their input is essential to the defense of this case. Therefore, for the reasons stated, the defendant moves the Court to continue this trial to December 20 or 27, 2005, or until a time in January 2006, that is convenient for the Court. \\\

Case 2:04-cr-01289-EHC

Document 73

Filed 09/23/2005

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Defense counsel has spoken with Assistant United States Attorney, Sharon Sexton concerning this motion, and the government has no objection to the requested continuance. Excludable delay under 18 U.S.C. § 3161(h)(8)(A) may result from this motion. Respectfully submitted: September 23, 2005. JON M. SANDS Federal Public Defender s/Jeffrey A. Williams JEFFREY A. WILLIAMS Asst. Federal Public Defender Copy of the foregoing MOTION TO CONTINUE TRIAL electronically transmitted by CM/ECF system this 23rd day of September, 2005, to: Sharon Sexton Assistant U.S. Attorney Two Renaissance Square, Suite 1200 40 North Central Avenue Phoenix, Arizona 850034-4408 I hereby certify that on 23rd day of September, 2005 the foregoing document was mailed on the following, who are not registered participants of the CM/ECF system: Eric Miguel Defendant s/Jeffrey A. Williams
JEFFREY A. WILLIAMS i:\miguel\4cont trial

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