Motion To Continue
DISTRICT COURT, COUNTY OF ADMAS STATE OF COLORADO 1100 Judicial Center Drive Brighton, CI 80601 Plaintiff: The People of the State of Colorado ? COURT USE ONLY ? Defendant: RICHARD E. STANLEY Case Number: 03-CR-2956 THE REISCH LAW FIRM, LLC R. Scott Reisch Stacey L. Ross 370 Seventeenth Street, Suite 4970 Div.: Ctrm.: Denver, CO 80202 Telephone: (303) 291-0555 FAX Number: (720) 904-5797 E-mail: rscottreisch@worldnet.att.net Atty. Reg. No.: 26892 Atty. Reg. No.: 20823 MOTION TO CONTINUE COMES NOW the defendant, Richard Stanley, by and through his attorneys, The Reisch Law Firm, and hereby moves to continue the motions filing deadline, the motions hearing, and the trial in this case. Further, defendant hereby tenders a waiver of his right to a speedy trial. AS GROUNDS THEREFORE, defendant states as follows: 1. Defendant only recently retained The Reisch Law Firm to represent him. 2. Given the complexity of the issues in this case, undersigned counsel will not have adequate time to review the discovery and research legal issues that must be litigated. 3. Undersigned counsel is authorized to waive defendant's right to a speedy trial so that the motions hearing and the trial can be re-set. 4. Defendant further waives his appearance at any hearing that would be held for the purpose of resetting the motions filing deadline, the motions hearing and the trial in this case. 5. Undersigned counsel has not been able to ascertain whether the deputy district attorney assigned to this matter has any objection to defendant's request. WHEREFORE, defendant requests that this motion be granted. DATED this ______ day of December 2003. Respectfully submitted, _______________________ R. Scott Reisch Stacey L. Ross CERTIFICATE OF SERVICE I do hereby certify that on the ____ day of December 2003, I ? deposited in the U.S. Mail, or ? sent via facsimile to the following number: ___________ or ? hand delivered the foregoing MOTION TO CONTINUE to the following: District Attorney's Office 450 South 4th Ave. Brighton, CO 80601
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Email Rick Stanley at rick@stanley2002.org |