Free Motion to Continue Trial - District Court of Arizona - Arizona

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PAUL K. CHARLTON United States Attorney District of Arizona JOHN R. LOPEZ, IV Assistant U.S. Attorney Two Renaissance Square 40 N. Central Avenue, Suite 1200 Phoenix, Arizona 85004-4408 Arizona State Bar No. 019182 Telephone (602) 514-7500 [email protected]

UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA United States of America, CR-03-1098-PHX-EHC Plaintiff, v. Jeanette B. Wilcher, Defendant. The United States, through undersigned counsel, and the Defendant, Jeanette Wilcher, through her counsel, jointly request the Court to continue the trial date of this matter from January 4, 2006, to April 4, 2006. This requested continuance stems from the inability of Larry Carr, a critical witness, to appear for trial on January 4, 2006. Mr. Carr is presently undergoing surgery and treatment for serious medical conditions described by letters from two of his physicians. Mr. Carr has been consulted and has advised the government he would likely be physically able to travel to testify at trial by late March 2006. The government has shared this information with defense counsel. Defense counsel has consulted with her client and her client agrees to this continuance. JOINT MOTION TO CONTINUE THE TRIAL

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Case 2:03-cr-01098-EHC

Document 174

Filed 12/22/2005

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For the reasons discussed above, both parties request a continuance of the trial until April 4, 2006, a date convenient to both parties, or until a later date convenient to the Court.

Respectfully submitted this 22nd day of December, 2005. PAUL K. CHARLTON United States Attorney District of Arizona /S/ John R. Lopez IV JOHN R. LOPEZ, IV Assistant U.S. Attorney

JON M. SANDS Federal Public Defender /S/ Deborah Euler-Ajayi DEBORAH L. EULER-AJAYI Assistant Federal Public Defender

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Case 2:03-cr-01098-EHC

Document 174

Filed 12/22/2005

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CERTIFICATE OF SERVICE I hereby certify that on December 22, 2005, I electronically transmitted the attached document to the Clerk's Office using the CM/ECF system for filing and transmittal of a Notice of Electronic Filing to the following CM/ECF registrants: Deborah Euler-Ajayi Asst. Federal Public Defender 850 W. Adams Street, Suite 201 Phoenix, Arizona 85007 Attorney for Defendant / S/ JOHN R. LOPEZ IV

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Case 2:03-cr-01098-EHC

Document 174

Filed 12/22/2005

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