Free Motion to Continue - District Court of Arizona - Arizona

JON M. SANDS Federal Public Defender 2 District of Arizona 850 W. Adams Street, Ste. 201 3 Phoenix, Arizona 85007 Telephone: (602) 382-2727
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MILAGROS A. CISNEROS, #020410 [email protected] 6 Asst. Federal Public Defender Attorney for Defendant
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IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA United States of America, Plaintiff, vs. Judith Ann Theede, Defendant. Judith Theede, through undersigned counsel, respectfully requests that this Court continue the trial in this case until a date after March 16, 2006. The reason for this continuance is that Ms. Theede has been participating in the pretrial diversion program and it is anticipated that she will complete the pretrial diversion program on or about March 16, 2006. Undersigned counsel has contacted Paul Rood, the Assistant United States Attorney assigned to this case, concerning this motion and Mr. Rood has no objection to the requested continuance. Undersigned counsel has also contacted Ceci Foster, the Pretrial Services Officer who, until very recently, was supervising Ms. Theede, and Ms. Foster, similarly, has no objection to the requested continuance. Furthermore, Ms. Foster indicated that Ms. Theede has been in full compliance with the pretrial diversion program. Undersigned counsel also contacted Gilbert Lara, Ms. Theede's new pretrial No. CR 03-996-PHX-DGC MOTION TO CONTINUE TRIAL (Seventh Request) (Unopposed)

Case 2:03-cr-00996-DGC

Document 61

Filed 08/24/2005

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services officer and he also reported that there have been no problems with Ms. Theede's supervision. It is expected that excludable delay under Title 18 U.S.C. § 3161(h)(8)(A) and (h)(1)(F) may result from this motion or from an order based thereon. Respectfully submitted: August 24, 2005. JON M. SANDS Federal Public Defender

s/Milagros A. Cisneros MILAGROS A. CISNEROS Asst. Federal Public Defender

Copy of the foregoing transmitted by CM/ECF for filing this 24th day 12 of August, 2005, to:
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PAUL ROOD 14 Assistant United States Attorney Two Renaissance Square 15 40 North Central Avenue Suite 1200 16 Phoenix, Arizona 85004-4408
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Copy mailed to:

GILBERT LARA U.S. Pretrial Services 401 West Washington 20 Phoenix, Arizona 85003
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JUDITH THEEDE 22 Defendant
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s/Milagros A. Cisneros M. Cisneros

Case 2:03-cr-00996-DGC

Document 61

Filed 08/24/2005

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