Free Motion to Continue - District Court of Arizona - Arizona

1 JON M. SANDS Federal Public Defender 2 850 W. Adams, Ste 201 Phoenix, Arizona 85007 3 Telephone: 602-382-2700 4 DAVID LEE TITTERINGTON State Bar # 006500 5 Asst. Federal Public Defender [email protected] 6 Attorney for Defendant 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 vs. William Domingo, Defendant. United States of America, Plaintiff, No. CR-04-1100-PHX-DGC MOTION TO CONTINUE TRIAL AND MOTION TO VACATE THE STATUS CONFERENCE (Sixth Request) IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA

Defendant William Domingo, by and through undersigned counsel, hereby respectfully requests this Court continue the trial date from January 10, 2006, for a period of thirty (30) days. A continuance is necessary to allow the parties to schedule and complete a settlement conference, which may be helpful in resolving this matter prior to trial. Defense counsel has spoken to Tom Simon, the Assistant United States Attorney assigned to this case, and he agrees that a settlement conference would be helpful in an attempt to negotiate a plea. For that reason, Mr. Domingo asks this Court to continue the trial for a period of 30 days. Defendant further requests that this Court vacate the Status Conference currently set for Thursday, December 22, 2005, at 10:00 a.m. Excludable delay under 18 U.S.C. § 3161(h)(1)(F) and (8)(A) will occur as a result of this motion or from an order based thereon. ....

Case 2:04-cr-01100-DGC

Document 22

Filed 12/19/2005

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Respectfully submitted: December 19, 2005. JON M. SANDS Federal Public Defender s/ David Lee Titterington DAVID LEE TITTERINGTON Assistant Federal Public Defender

8 Copy of the foregoing transmitted by CM/ECF for filing this 19th day 9 of December, 2005, to: 10 Clerk's Office United States District Court 11 Sandra Day O'Connor Courthouse 401 W. Washington 12 Phoenix, Arizona 85003 13 Tom Simon Assistant U.S. Attorney 14 United States Attorney's Office Two Renaissance Square 15 40 N. Central Avenue, Suite 1200 Phoenix, Arizona 85004-4408 16 Copy mailed to: 17 William Domingo 18 Defendant 19 s/ Kathy A. Kruckeberg 20 Kathy A. Kruckeberg 21 22 23 24 25 26 27 28 2
Case 2:04-cr-01100-DGC Document 22 Filed 12/19/2005 Page 2 of 2