MICHAEL NANCE

ATTORNEY AT LAW

615 SECOND AVENUE, SUITE 760

SEATTLE, WASHINGTON 98104

(206) 624-3211

1

Honorable Marsha Pechman

UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF WASHINGTON, SEATTLE

UNITED STATES OF AMERICA, )

) No. CR05-185P

Plaintiff, ) 

) STIPULATION AND AGREED 

v. ) ORDER CONTINUING MOTION

) CUTOFF DATE

CYNTHIA ANAYA-CONTRERAS, )

)

Defendant. )

____________________________________)

Stipulation 

The United States of America, by and through John McKay, United States Attorney for

the Western District of Washington, and Lawrence Lincoln, Assistant United States Attorney, and

defendant Cynthia Anaya-Contreras, by and through her undersigned counsel, Michael Nance,

hereby stipulate and agree as follows:

The defendant, together with others, is charged in a multi-count indictment with

conspiracy to distribute methamphetamine and cocaine and several substantive counts of

distribution of methamphetamine, all in violation of 21 USC § 841(b)(1)(A).

A trial date has been scheduled for July 11, 2005. The pre-trial motion cutoff date for Ms.

Anaya-Contreras is currently June 2, 2005. 

To date, the defense is still reviewing discovery only recently received. No previous

continuance of the cutoff date has been sought. Government counsel expects to be in trial on

Case 2:05-cr-00185-MJP Document 46 Filed 06/03/05 Page 1 of 4
MICHAEL NANCE

ATTORNEY AT LAW

615 SECOND AVENUE, SUITE 760

SEATTLE, WASHINGTON 98104

(206) 624-3211

2

another case during the week of June 20, 2005.

The parties believe additional time within which to file pretrial motions would facilitate a

more meaningful evaluation of the evidence, promote informed plea discussions on each side, and

allow for a more cogent presentation of issues, if any, by way of motion. 

For these reasons the parties agree that the pretrial motion cutoff should be continued

until June 16, 2005. In view of the fact that government counsel is in trial beginning June 20, the

government shall have until June 30, 2005, to respond to any filed defense motions. 

Dated this 2nd day of June, 2005.

/s/ Lawrence Lincoln - by telephone permission - MCN /s/ Michael Nance

Lawrence Lincoln Michael Nance, WSBA # 13933

Assistant United States Attorney Defense Attorney 

Case 2:05-cr-00185-MJP Document 46 Filed 06/03/05 Page 2 of 4
MICHAEL NANCE

ATTORNEY AT LAW

615 SECOND AVENUE, SUITE 760

SEATTLE, WASHINGTON 98104

(206) 624-3211

3

ORDER

For the reasons set forth in the foregoing stipulation, the court orders that the pre-trial

motions cutoff be extended to June 16, 2005. The government shall have until June 30, 2005, to

file a response.

Dated this __3rd __ day of June, 2005.

AMarsha J. Pechman

U.S. District Judge

Presented by:

/s/ Michael Nance

Michael Nance

Defense Attorney

Case 2:05-cr-00185-MJP Document 46 Filed 06/03/05 Page 3 of 4
MICHAEL NANCE

ATTORNEY AT LAW

615 SECOND AVENUE, SUITE 760

SEATTLE, WASHINGTON 98104

(206) 624-3211

4

CERTIFICATE OF SERVICE

I hereby certify that on the 2nd day of June, 2005, I electronically filed the foregoing with

the clerk of the court using the CM/ECF system. Notice of this filing will be sent electronically to

attorneys of record for all parties.

_/s/ Michael Nance_____________

Michael Nance,WSBA # 13933

Email: minance@aolcom

Attorney for defendant Cynthia Anaya-Contreras

Case 2:05-cr-00185-MJP Document 46 Filed 06/03/05 Page 4 of 4