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

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Theron M Hall III T h e H a l l F i r m p. c. State Bar Number 019114 One Renaissance Square Two North Central Avenue Suite 735 Phoenix, AZ 85004 (602) 222­6699 Fax (602) 443­2221

Attorney for Defendant IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA

United States of America, Plaintiff, v. Kristina Ingles (04) Defendant

Case No. CR-03-854-PHX-JAT DEFENDANT'S MOTION TO COTINUE TRIAL DATE

Defendant Kristina Ingles, through undersigned counsel, respectfully requests that this Court continue the trial date for a period of six months from the

16 17 18 19 20 21 22 23 24 25 matter. Likewise, it appears that co-defendant Rebecca Williams is also enrolled in a Pretrial Diversion Program. Due to the amount of time still remaining in the Pretrial Diversion Program, a continuance of six (6) months is therefore requested. current date of August 1, 2006. It is also requested that the court vacate the Status Conference set for July 19, 2006. Defendant Kristina Ingles is enrolled in a Pretrial Diversion Program in this

Case 2:03-cr-00854-LOA

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Filed 06/29/2006

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Assistant U.S. Attorney Paul Rood does not oppose this objection. Likewise, Mark Berardoni, counsel for defendant Rebecca Williams, does not oppose this motion. It is expected that excludable delay under Title 18 U.S.C. Section 3161(h)________ may occur as a result of this motion or from an order based thereon. Respectfully submitted this 29th day of June, 2006.

s/Theron M Hall III Theron M Hall III

Case 2:03-cr-00854-LOA

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Filed 06/29/2006

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