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

1 JON M. SANDS Federal Public Defender 2 District of Arizona 850 West Adams Street, Ste. 201 3 Phoenix, Arizona 85007 Telephone: (602) 382-2739 4 JEFFREY A. WILLIAMS; #012605 5 jeffrey_williams @fd.org Asst. Federal Public Defender 6 Attorney for Defendant 7 8 9 10 11 12 13 14 15 Defendant, Randy Earl Wright, by and through undersigned counsel, 16 respectfully moves that this Court extend the time for filing of pretrial motions for a 17 period of thirty (30) days from the February 24, 2006. In addition, defendant moves 18 that the Court continue the trial date for a period of at least thirty (30) days from the 19 date of March 14, 2006. The reasons for continuance is to complete the discovery 20 process. 21 Defense counsel has contacted Assistant United States Attorney Kurt 22 Altman of the contents of this motion and has no objection to the requested 23 continuance. Additionally, defense counsel contacted attorney Daniel Raynak for 24 co-defendant Jason Eugene Jeffries who has no indicated no objection to the 25 requested continuance. 26 . . . 27 . . . 28 . . . vs. Randy Earl Wright, et al. Defendant. IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA United States of America, Plaintiff, No. CR-04-1172-PHX-DGC MOTION TO CONTINUE TRIAL AND EXTENSION OF PRETRIAL MOTION DEADLINE (Fourth Request)

Case 2:04-cr-01172-DGC

Document 72

Filed 02/23/2006

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Excludable delay under 18 U.S.C. § 3161(h)(8)(A) and (h)(1)(F) may Respectfully submitted: February 23, 2006. JON M. SANDS Federal Public Defender s/Jeffrey A. Williams JEFFREY A. WILLIAMS Asst. Federal Public Defender

2 result from this motion or from an order based thereon.

Copy of the foregoing electronically 9 transmitted by CM/ECF system this 23rd day of February, 2006, to: 10 KURT ALTMAN 11 Assistant United States Attorney Two Renaissance Square 12 40 North Central Avenue Suite 1200 13 Phoenix, Arizona 85004-4408 14 DANIEL RAYNAK 15 45 W Jefferson St Suite 225 Phoenix, AZ 85003-2325 16 Attorney for Co-Defendant 17 Copy mailed to: 18 RANDY WRIGHT Defendant 19 s/Jeffrey A. Williams 20 JEFFREY A. WILLIAMS 21 \ContinueM TN 22 23 24 25 26 27 28 2

Case 2:04-cr-01172-DGC

Document 72

Filed 02/23/2006

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