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

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Michael B. Bernays State Bar # 007057 111 West Monroe Phoenix, AZ 85003 (602) 254-5544 Attorney for Defendant

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UNITED STATED DISTRICT COURT DISTRICT OF ARIZONA UNITED STATES OF AMERICA Plaintiff, vs. SHEILA M. ISABELL, Defendant ) ) ) ) ) ) ) ) Case No.: CR 03-1082-001-PHX-MHM

MOTION TO CONTINUE JURY TRIAL

The Defendant, Sheila Isabell, through counsel, Michael B. Bernays, hereby moves the Court to continue the Jury Trial currently scheduled for May 16, 2006 at 9:30 a.m., on the grounds that counsel has requested discovery and has been informed by the government that they are in the process of preparing that discovery for disclosure. Given Ms. Isabell's location in Ohio and the difficulty in travel due to her indigency, Counsel will need time to copy and forward that disclosure to Ms. Isabell for her review. Counsel would therefore request a continuance of at least 45 days to accomplish these tasks. Counsel has spoken with Assistant United States Attorney John Lopez, who has authorized counsel to state that the government does not oppose this motion. For all the forgoing reasons, counsel would request the court to grant the Motion to Continue and continue the jury trial for approximately 45 days. Excludable delay pursuant to 18 USC § 3161(h)(8)(A) will occur as a result of this motion. RESPECTFULLY SUBMITTED this 10th day of May, 2006. s/ Michael B. Bernays Michael B. Bernays 111 West Monroe Phoenix, AZ 85003 Attorney for Defendant

Case 2:03-cr-01082-MHM

Document 48

Filed 05/10/2006

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Copy of the foregoing filed via EFC this 10th day of May, 2006, to: John Lopez Assistant U.S. Attorney 40 North Central Avenue, Ste. 1200 Phoenix, AZ 85004-4408 By: s/ Michael B. Bernays

Case 2:03-cr-01082-MHM

Document 48

Filed 05/10/2006

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