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 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 (Fourth Request) Defendant William Domingo, by and through undersigned counsel, IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA

17 hereby respectfully requests this Court to extend the pretrial motions deadline for a 18 period of twenty (20) days from the new trial date. Defendant further requests that 19 this Court continue the trial date from September 13, 2005, for a period of sixty (60) 20 days. This is a very complicated murder case and defense counsel needs the 21 additional time for further investigation. This case has many witnesses located 22 throughout the Indian Reservation. Additionally, defense counsel will be out of town 23 from September 10, 2005, to September 24, 2005. Defendant further requests that 24 this Court vacate the Status Conference currently set for Monday, August 29, 2005, 25 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. 28 . . . .

Case 2:04-cr-01100-DGC

Document 15

Filed 08/24/2005

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Excludable delay under 18 U.S.C. § 3161(h)(1)(F) and (8)(A) will occur Respectfully submitted: August 24, 2005. JON M. SANDS Federal Public Defender s/ David Lee Titterington DAVID LEE TITTERINGTON Assistant Federal Public Defender

2 as a result of this motion or from an order based thereon.

10 Copy of the foregoing transmitted by CM/ECF for filing this 24th day 11 of August, 2005, to: 12 Clerk's Office United States District Court 13 Sandra Day O'Connor Courthouse 401 W. Washington 14 Phoenix, Arizona 85003 15 Tom Simon Assistant U.S. Attorney 16 United States Attorney's Office Two Renaissance Square 17 40 N. Central Avenue, Suite 1200 Phoenix, Arizona 85004-4408 18 Copy mailed to: 19 William Domingo 20 Defendant 21 s/ David Lee Titterington 22 DAVID LEE TITTERINGTON 23 Assistant Federal Public Defender 24 25 26 27 28 2
Case 2:04-cr-01100-DGC Document 15 Filed 08/24/2005 Page 2 of 2