Free Motion to Continue - District Court of Arizona - Arizona

1 JON M. SANDS Federal Public Defender 2 District of Arizona 3 850 W. Adams Street, Ste. 201 Phoenix, Arizona 85007 4 Telephone: (602) 382-2729 5 JANE L. McCLELLAN AZ State Bar No. #015902 6 Asst. Federal Public Defender [email protected] 7 Attorney for Defendant 8 9 10 11 12 13 14 15 16 v. Timothy Wayne Isabell, Defendant. United States of America, No. CR-03-1082-PHX-MHM Plaintiff, MOTION TO CONTINUE TRIAL AND MOTION TO EXTEND THE PRETRIAL MOTIONS DEADLINE (Third Request) IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA

Defendant Timothy Wayne Isabell, by and through undersigned counsel,

17 hereby respectfully requests that this Court extend the pretrial motions deadline from 18 the current date of March 10, 2006, for a period of thirty (30) days. Defendant further 19 requests that this Court continue the trial date from April 11, 2006, for a period of 20 thirty (30) days. Defendant needs additional time to review the discovery and to 21 22 conduct further investigation and research. Defense counsel also needs additional 23 time to consult with the defendant. 24 Defense counsel has contacted Assistant United States Attorney John 25 Lopez concerning this motion, and he has no objection to this motion. 26 . . . . 27 28 .... ....

Case 2:03-cr-01082-MHM

Document 23

Filed 03/07/2006

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It is expected that excludable delay under Title 18 U.S.C. §3161(h)(1)(F)

2 will occur as a result of this motion or from an order based thereon. 3 Respectfully submitted: March 7, 2006. 4 5 6 7 8 9 10 11 Copy of the foregoing transmitted 12 by CM/ECF for filing this 7th day of March, 2006, to: 13 Clerk's Office 14 United States District Court Sandra Day O'Connor Courthouse 15 401 W. Washington 16 Phoenix, Arizona 85003 17 John Lopez Assistant U.S. Attorney 18 Two Renaissance Square 40 North Central Ave., Ste. 1200 19 Phoenix, Arizona 85003 20 Copy mailed to: 21 23 Timothy Wayne Isabell 22 Defendant s/ Kathy A, Kruckeberg 24 Kathy A. Kruckeberg 25 26 27 28
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JON M. SANDS Federal Public Defender

s/ Jane L. McClellan JANE L. McCLELLAN Asst. Federal Public Defender

Case 2:03-cr-01082-MHM

Document 23

Filed 03/07/2006

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