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 vs. William Domingo, Defendant. United States of America, Plaintiff, No. CR-04-1100-PHX-DGC MOTION TO CONTINUE TRIAL AND MOTION TO EXTEND THE PRETRIAL MOTION DEADLINE AND MOTION TO VACATE THE STATUS CONFERENCE (Fifth Request) Defendant William Domingo, by and through undersigned counsel, IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA

18 hereby respectfully requests this Court to extend the pretrial motions deadline for a 19 period of thirty (30) days. Defendant further requests that this Court continue the trial 20 date from November 8, 2005, for a period of forty-five (45) days. This is a very 21 complicated murder case and defense counsel needs the additional time for further 22 investigation. This case has many witnesses located throughout the Indian 23 Reservation. Additionally, the parties are proceeding forward in an attempt to resolve 24 this case short of trial. Defendant further requests that this Court vacate the Status 25 Conference currently set for Monday, October 24, 2005, at 1:30 p.m. 26 Defense counsel has contacted the Assistant U.S. Attorney assigned to 27 this case, Thomas Simon, and the government has no objection to this continuance. Excludable delay under 18 U.S.C. § 3161(h)(1)(F) and (8)(A) will occur 28 as a result of this motion or from an order based thereon.
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Respectfully submitted: October 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 October, 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
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