Free Motion to Continue - District Court of Arizona - Arizona

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

ANN E M . W ILL IAM S, P.C. ANNE M . WILLIAMS # 012414 amw illiams@ cox.net Attorney at Law 1833 East Baseline Road - PMB 265 Gilbert, Arizona 85233-1545 (T) 480.892.7177 (F) 480.471.6652 Attorney for Charles Tyrone Harris

IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA

United States of America, 2:04-cr-01058-002-PHX-FJM Plaintiff, v. MOTION TO CONTINUE TRIAL AND EXTEND TIME TO FILE PRETRIAL MOTIONS AND PROPOSED FORM OF ORDER (First Request) Defendant.

CHARLES TYRONE HARRIS,

Charles Tyrone Harris, through undersigned counsel, moves this Court to continue the trial date of January 4, 2006, for an additional sixty (60) days. Mr. Harris was arraigned on December 6, 2005, and Counsel for Mr. Harris was appointed at that time. Counsel has not yet received discovery nor had adequate time to prepare for trial. Mr. Harris further requests this Court extend time to file pretrial motions for an additional forty-five (45) days from the current date. Assistant U.S. Attorney, Kurt Altman, has been contacted on two occasions with regard to this motion and has not returned Counsel's call indicating whether he had any objection to the requested continuance. All other Counsel assigned to named co-defendants have been contacted. They have indicated that their clients have entered into changes of plea and are set for sentencing.

Case 2:04-cr-01058-FJM

Document 60

Filed 12/08/2005

Page 1 of 2

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

Therefore, the requested continuance for trial does not affect their clients. It is expected that excludable delay under Title 18 U.S.C. Section 3161(h)(1)(F) may occur as a result of this motion or from an order based thereon.

Respectfully submitted: December 8, 2005.

/S/ ANNE M. WILLIAMS ANNE M. WILLIAMS, P.C.

Copy of the foregoing served this date via transmittal of Notice of Electronic Filing to CM /ECF reg istrant(s): Mr. Kurt Altman [email protected] As sistan t U.S. Attorney M s. An ne M. W illia m s amw illiams@ cox.net Counsel for Mr. Harris

2

Case 2:04-cr-01058-FJM

Document 60

Filed 12/08/2005

Page 2 of 2