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 August 23, 18 2005 for a period of at least sixty (60) days. A continuance is necessary on the basis 19 that the parties are working on Mr. Draper's acceptance into the U.S. Pre-Trial 20 Services Diversion Program, and therefore, additional time is needed for further 21 investigation. 22 Assistant U.S. Attorney, Paul V. Rood, has been contacted with regard 23 to this motion and he has no objection to the requested continuance. 24 Defendant further requests that any subpoenas previously issued and 25 served in this matter remain in effect and the party who served the subpoena should 26 27 28 advise the witnesses of the new trial date. ... ... vs. Jeffrey S. Draper, Defendant. United States of America, Plaintiff, No. CR-04-1174-PHX-MHM MOTION TO CONTINUE TRIAL (Sixth Request) IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA

Case 2:04-cr-01174-MHM

Document 27

Filed 08/10/2005

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It is expected that excludable delay under Title 18 U.S.C. §

2 3161(h)(8)(A) may occur as a result of this motion or from an order based thereon. 3 Respectfully submitted: August 10, 2005. 4 5 6 7 8 9 Copy of the foregoing transmitted CM/ECF this 10th 10 by August, 2005, to: day of 11 PAUL V. ROOD 12 Assistant United States Attorney Two Renaissance Square 13 40 North Central Avenue Suite 1200 14 Phoenix, Arizona 85004-4408 15 Copy mailed to: 16 JEFFREY S. DRAPER 17 Defendant 18 20 21 22 23 24 25 26 27 28
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\Trial6MTN

JON M. SANDS Federal Public Defender

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

s/Donna Lee Elm 19 DONNA LEE ELM

Case 2:04-cr-01174-MHM

Document 27

Filed 08/10/2005

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