Free Motion to Continue - District Court of Arizona - Arizona

1 JON M. SANDS Federal Public Defender 2 District of Arizona 850 W. Adams Street, Ste. 201 3 Phoenix, Arizona 85007 4 Telephone: (602) 382-2753 5 Donna Lee Elm, #12127 Asst. Federal Public Defender 6 Attorney for Defendant [email protected] 7 8 9 10 11 12 13 14 15 16 17 Jeffrey S. Draper moves to continue trial currently set for January 10, 18 2006 or a period of at least eighteen (18) months. A continuance is sought because 19 Mr. Draper has just been accepted into, and has started serving, his eighteen (18) 20 month period of supervision under the U.S. Pre-Trial Services Diversion Program. 21 23 Assistant U.S. Attorney, Paul Rood, has been contacted with regard to 22 this motion and he has no objection to the requested continuance. It is expected that excludable delay under Title 18 U.S.C. § 24 3161(h)(8)(A) may occur as a result of this motion or from an order based thereon. 25 ... 26 27 28 ... ... vs. Jeffrey S. Draper, Defendant. United States of America, Plaintiff, No. CR-04-1174-PHX-MHM MOTION TO CONTINUE TRIAL (Eighth Request) IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA

Case 2:04-cr-01174-MHM

Document 31

Filed 12/09/2005

Page 1 of 2

1 2 3 4 5 6

Respectfully submitted: December 9, 2005. JON M. SANDS Federal Public Defender

s/Donna Lee Elm DONNA LEE ELM Asst. Federal Public Defender

7 Copy of the foregoing transmitted by CM/ECF this 9th day 8 of December, 2005, to: 9 PAUL V. ROOD 10 Assistant United States Attorney Two Renaissance Square 11 40 North Central Avenue Suite 1200 12 Phoenix, Arizona 85004-4408 13 MICHELLE COLE Pre-Trial Services 14 U.S. Courthouse 401 West Washington Street 15 Phoenix, AZ 85007 16 Copy mailed to: 17 JEFFREY S. DRAPER 18 Defendant 19 21 22 23 24 25 26 27 28
2

s/Donna Lee Elm 20 DONNA LEE ELM

Case 2:04-cr-01174-MHM

Document 31

Filed 12/09/2005

Page 2 of 2