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LAW OFFICE OF

ZENON PETER OLBERTZ

1008 SOUTH YAKIMA AVENUE, SUITE 302

TACOMA, WASHINGTON 98405

(253) 272-9967

STIPULATED MOTION AND ORDER FOR

CONTINUANCE OF TRIAL, PRETRIAL

CONFERENCE AND PRETRIAL MOTIONS

CUTOFF DATE - 1

THE HONORABLE FRANKLIN D. BURGESS

UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF WASHINGTON

AT TACOMA

UNITED STATES OF AMERICA,

Plaintiff, 

v.

JONATHAN MOAMLAE, EDWARD

MALANDO WILLIAMS AND MAZZAR

GERALD ROBINSON,

Defendants.

CASE NO. CR05-5784FDB

STIPULATED MOTION AND

ORDER FOR CONTINUANCE OF

TRIAL, PRETRIAL CONFERENCE

AND PRETRIAL MOTIONS

CUTOFF DATE

The defendants herein, Edward MalandoWilliams, by and through his counsel, Zenon P.

Olbertz; Mazzar Gerald Robinson, by and through his counsel, Judith M. Mandel; and the

Government, by and through its counsel, Kent Y. Liu, Special Assistant U.S. Attorney, hereby

move that the trial presently scheduled for January 17th, 2006, be vacated, and that the trial be

rescheduled to March 27th, 2006 at 9:00 a.m., and that the pretrial conference presently

scheduled for January 5, 2006, be vacated and that the pretrial conference be rescheduled to a

date to be determined by the court. Parties further move that the pretrial motions cutoff date

presently scheduled for December 15, 2005, be vacated and that the pretrial motions cutoff date

Case 3:05-cr-05784-RBL Document 36 Filed 12/22/05 Page 1 of 5
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LAW OFFICE OF

ZENON PETER OLBERTZ

1008 SOUTH YAKIMA AVENUE, SUITE 302

TACOMA, WASHINGTON 98405

(253) 272-9967

STIPULATED MOTION AND ORDER FOR

CONTINUANCE OF TRIAL, PRETRIAL

CONFERENCE AND PRETRIAL MOTIONS

CUTOFF DATE - 2

be reschedule to a date to be determined by the court.

The above request for continuance is being made as a result of the need for additional

time to review the over 400 pages of discovery recently provided to defense counsel and the

need for time to contact and interview witnesses listed in said discovery in preparation for trial

and pretrial motions.. 

All defendants agree to waive their right to speedy trial to the date of April 14th, 2006,

and will file said waivers of speedy trial with this court.

The parties believe that the ends of justice would be served by a continuance of the trial,

pretrial conference, and the pretrial motions cutoff date in this matter.

DATED this 14th, day of December, 2005.

 /s/ /s/

By: _________________________ By: 

 Zenon P. Olbertz, WSB #6080 Judith M. Mandel, WSB #8677

 Attorney for Edward M. Williams Attorney for Mazzar G. Robinson

 

/s/ 

By: _________________________ 

 Kent Y. Liu, WSB #21599

 Special Assistant U.S. Attorney 

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LAW OFFICE OF

ZENON PETER OLBERTZ

1008 SOUTH YAKIMA AVENUE, SUITE 302

TACOMA, WASHINGTON 98405

(253) 272-9967

STIPULATED MOTION AND ORDER FOR

CONTINUANCE OF TRIAL, PRETRIAL

CONFERENCE AND PRETRIAL MOTIONS

CUTOFF DATE - 3

ORDER

Before this court is a stipulated motion for continuance of the trial, pretrial conference

and pretrial motions cutoff date (presently scheduled as follows: trial/January 17th, 2006; pretrial

conference/January 5th, 2006, and pretrial motions cutoff/December 15th, 2005). The court

finds, after a consideration of all relevant information and the circumstances of this case, that

without this continuance the defendants will be prejudiced and the ability to properly prepare for

trial would be impaired. Failure to grant a continuance under these circumstances would result

in a miscarriage of justice. The ends of justice would best be served by granting of the motion

for continuance. The ends of justice outweigh the best interests of the public and the defendants

in a speedy trial.

For these reasons, the court finds the stipulated motion for continuance should be granted.

The previously scheduled trial date is hereby VACATED. The trial shall be RESCHEDULED

to March 27th, 2006 at 9:00 a.m. The previously scheduled pretrial conference date is hereby

VACATED. The pretrial conference shall be RESCHEDULED to March 17, 2006 at 3:30 p.m. 

***

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LAW OFFICE OF

ZENON PETER OLBERTZ

1008 SOUTH YAKIMA AVENUE, SUITE 302

TACOMA, WASHINGTON 98405

(253) 272-9967

STIPULATED MOTION AND ORDER FOR

CONTINUANCE OF TRIAL, PRETRIAL

CONFERENCE AND PRETRIAL MOTIONS

CUTOFF DATE - 4

The previously schedule pretrial motions cutoff date is hereby VACATED. The pretrial

motions cutoff shall be RESCHEDULED to January 25, 2006. 

IT IS SO ORDERED.

DONE this 22nd day of December, 2005.

AFRANKLIN D. BURGESS

UNITED STATES DISTRICT JUDGE

 /s/ /s/

By: _________________________ By: 

 Zenon P. Olbertz, WSB #6080 Judith M. Mandel WSB #8677

 Attorney for Edward M. Williams Attorney for Mazzar G. Robinson

 

/s/ 

By: _________________________ 

 Kent Y. Liu, WSB #21599

 Special Assistant U.S. Attorney

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LAW OFFICE OF

ZENON PETER OLBERTZ

1008 SOUTH YAKIMA AVENUE, SUITE 302

TACOMA, WASHINGTON 98405

(253) 272-9967

STIPULATED MOTION AND ORDER FOR

CONTINUANCE OF TRIAL, PRETRIAL

CONFERENCE AND PRETRIAL MOTIONS

CUTOFF DATE - 5

 CERTIFICATE OF SERVICE

I hereby certify that on December 14th, 2005, I electronically filed the foregoing

Stipulated Motion and Order for Continuance of Trial, Pretrial Conference and Pretrial Motions

Cutoff Date with the Clerk of the Court using the CM/ECF system which will send notification

of such filing to the following:

Kent Y. Liu

Special Assistant United States Attorney

1201 Pacific Avenue, Suite 700

Tacoma, WA 98402

Jerome Kuh

Federal Public Defender’s Office

1331 Broadway, Suite 400

Tacoma, WA 98402

Judith M. Mandel

Attorney at Law

524 Tacoma Avenue So.

Tacoma, WA 98402

I hereby certify that on December 14th, 2005, I mailed the Stipulated Motion and Order

for Continuance of Trial, Pretrial Conference and Pretrial Motions Cutoff Date to the following:

Edward Malando Williams

Reg. #35730-086

FDC at SeaTac

P.O. Box 13900

Seattle, WA 98198

DATED this 14th, day of December, 2005.

/s/

 

Sarah M. Heckman

Legal Assistant

Case 3:05-cr-05784-RBL Document 36 Filed 12/22/05 Page 5 of 5