UNOPPOSED MOTION AND ORDER CONTINUING 

 TRIAL DATE (CASE NO. CR 06-0101-JLR) - 1 

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 WOLFE LEINBACH, P.S. 

Attorney at Law 

 701 Fifth Avenue, Suite 6110 

Seattle, WA 98104 

(206) 467-9088 

Fax: (206) 447-9374 

The Honorable James L. Robart 

UNITED STATES DISTRICT COURT 

FOR THE WESTERN DISTRICT OF WASHINGTON 

AT SEATTLE 

UNITED STATES OF AMERICA 

 Plaintiff, 

 v. 

RICHARD KEITH LATMAN, 

 Defendant. 

No. CR 06-0101-JLR 

UNOPPOSED MOTION AND ORDER 

CONTINUING TRIAL DATE 

Note on Motion Calendar: 

May 12, 2006 

I. UNOPPOSED MOTION. 

The defendant, Richard Keith Latman, by and through his attorney, WOLFE 

LEINBACH, P.S, and John W. Wolfe, moves this Court for an order sticking the current June 

13, 2006 trial date and continuing this case until Tuesday, September 19, 2006. This motion is 

based upon the following facts and supported by the accompanying declaration of John W. 

Wolfe: 

1. On March 23, 2006, Mr. Latman was charged in a three count indictment with 

Conspiracy to Conceal Assets and Make False Oaths and False Statements, 

Count 1 and Concealing Assets, Counts 2 and 3. Mr. Latman voluntarily 

appeared before this Court and was arraigned on Thursday, April 6. 2006. He 

was released on an Appearance Bond pending trial. Trial is currently 

scheduled to commence on June 13, 2006. 

Case 2:06-cr-00101-JLR Document 9 Filed 05/08/06 Page 1 of 4
UNOPPOSED MOTION AND ORDER CONTINUING 

 TRIAL DATE (CASE NO. CR 06-0101-JLR) - 2 

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 WOLFE LEINBACH, P.S. 

Attorney at Law 

 701 Fifth Avenue, Suite 6110 

Seattle, WA 98104 

(206) 467-9088 

Fax: (206) 447-9374 

2. This case is reasonably complex. Discovery involves voluminous documents 

which are being electronically scanned and which will be produced to defense 

counsel in electronic form. Thereafter, defense counsel will be required to 

convert these electronic images to hard, paper copies. In addition, the 

government anticipates that there may be “a number” of out of State 

witnesses. 

3. Defense Counsel has professional scheduling conflicts that prevent him from 

being able to prepare for and try this case during May and June and personal 

scheduling conflicts would conflict with his being prepared to try this case 

before September 2006. 

4. In addition, Mr. Richard Latman, the defendant herein, has scheduling 

conflicts which require a continuance of this case until September, 2006 and 

has executed a Waiver of Speedy Trial Rights which accompanies this 

Unopposed Motion and Order. 

5. Failure to continue this case until September, 2006 will deny defense counsel 

reasonable time to effectively prepare for trial. 

6. The Court’s Docket Clerk has advised counsel that the Court could start this 

trial on Tuesday, September 19. 2006. 

7. Based upon the scheduling conflicts confronting defense counsel, the 

complexity of the case, and the various legal issues which counsel for both 

parties must address prior to trial, the parties believe that the interests of 

justice would best be served by continuing the trial date in this case until 

Tuesday, September 19, 2006. 

8. Assistant United States Attorney Donald Currie, who is assigned to prosecute 

this case, discussed this motion with defense counsel and does not opposed 

the entry of an order continuing the trial date until September 19, 2006 so 

Case 2:06-cr-00101-JLR Document 9 Filed 05/08/06 Page 2 of 4
UNOPPOSED MOTION AND ORDER CONTINUING 

 TRIAL DATE (CASE NO. CR 06-0101-JLR) - 3 

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 WOLFE LEINBACH, P.S. 

Attorney at Law 

 701 Fifth Avenue, Suite 6110 

Seattle, WA 98104 

(206) 467-9088 

Fax: (206) 447-9374 

long as the defendant, Richard Latman, executes a satisfactory speedy trial 

waiver. 

II. FINDINGS AND ORDER CONTINUING TRIAL DATE. 

 Based upon the factual recitals set forth above, the Court makes the following findings: 

1. The Court finds that a failure to continue this case until September 19, 

2006 would deny defense counsel reasonable time to effectively prepare 

for trial, taking into account the exercise of due diligence, within the 

meaning of 18 U.S.C. 3161 (h)(8)(B)(iv). 

2. The Court finds that the ends of justice served by continuing this case 

until September 19, 2006 so as to provide defense counsel with reasonable 

time to effectively prepare for trial outweigh the best interest of the public 

and the defendant in a speedy trial within the meaning of 18 U.S.C. 

3161(h)(8). 

IT IS THEREFORE ORDERED that the current trial date of June 13, 2006 is stricken 

and the trial date in this matter is continued until Tuesday, September 19, 2006 at 9:00 a.m. 

and the current deadline for filing pretrial motions is extended until July 20, 2006. 

IT IS FURTHER ORDERED that the period of time between the filing of the 

Defendant’s Unopposed Motion to Continue the Trial Date and the new trial date of 

September 19, 2006, shall be excludable time pursuant to the Speedy Trial Act, 18 U.S.C. 

3161. 

IT IS SO ORDERED. 

 DATED THIS 8th day of May, 2006. 

JAMES L. ROBART 

United States District Judge 

A

Case 2:06-cr-00101-JLR Document 9 Filed 05/08/06 Page 3 of 4
UNOPPOSED MOTION AND ORDER CONTINUING 

 TRIAL DATE (CASE NO. CR 06-0101-JLR) - 4 

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 WOLFE LEINBACH, P.S. 

Attorney at Law 

 701 Fifth Avenue, Suite 6110 

Seattle, WA 98104 

(206) 467-9088 

Fax: (206) 447-9374 

PRESENTED BY: 

WOLFE LEINBACH, P.S. 

/s/ John W. Wolfe 

John W. Wolfe 

Attorney for Richard Latman 

WSBA # 8028 

APPROVED AS TO ENTRY: 

UNITED STATES ATTORNEY 

WESTERN DISTRICT OF WASHINGTON 

Don Currie per email authorization 

Donald Currie 

Assistant United States Attorney 

Case 2:06-cr-00101-JLR Document 9 Filed 05/08/06 Page 4 of 4