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 (First 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 December 29, 2005, for a period of thirty (30) days. Defendant 19 further requests that this Court continue the trial date from January 31, 2006, for a 20 period of thirty (30) days. Defendant recently received the discovery and needs 21 22 additional time to review it and to conduct further investigation and research. 23 25 . . . . 26 . . . . 27 28 .... Defense counsel has contacted Assistant United States Attorney John 24 Lopez concerning this motion, and he has no objection to this motion.

Case 2:03-cr-01082-MHM

Document 14

Filed 12/28/2005

Page 1 of 2

1

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: December 28, 2005. 4 5 6 7 8 9 10 11 Copy of the foregoing transmitted 12 by CM/ECF for filing this 28th day of December, 2005, 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 24 25 26 27 28
2

JON M. SANDS Federal Public Defender

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

Timothy Wayne Isabell 22 Defendant s/ Kathy A, Kruckeberg Kathy A. Kruckeberg

Case 2:03-cr-01082-MHM

Document 14

Filed 12/28/2005

Page 2 of 2