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ORDER CONTINUING TRIAL 

AND PRETRIAL MOTIONS 

DEADLINE/CHANG 

CR06-254RSM-2 

 

 

ROBERT PEREZ 

Attorney at Law 

2018 156th Avenue NE Suite 100 

Bellevue, WA 98007 

(425) 748-5005 

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THE HONORABLE RICARDO S. MARTINEZ

UNITED STATES DISTRICT COURT 

 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 

UNITED STATES OF AMERICA, 

 Plaintiff, 

 vs. 

ALYSSA MARIE CHANG., 

 Defendants. 

NO. CR06-254RSM 

ORDER CONTINUING TRIAL AND 

PRETRIAL MOTIONS DEADLINE 

THIS MATTER comes before the Court on a stipulated motion of the defendant 

and the government and to continue the trial date and the pretrial motions deadline date. 

Having considered the entirety of the record and files herein, the Court finds that failure 

to grant a continuance would likely result in a miscarriage of justice. The case is 

complex requiring the parties to analyze bank records of the defendant and several 

witnesses. Although the grand jury returned an indictment on July 20, 2006, new defense 

counsel recently entered a notice of appearance on September 7, 2006, and requires 

additional time to prepare for trial. 

Case 2:06-cr-00254-RSM Document 21 Filed 11/17/06 Page 1 of 3
Page 2 

ORDER CONTINUING TRIAL 

AND PRETRIAL MOTIONS 

DEADLINE/CHANG 

CR06-254RSM-2 

 

 

ROBERT PEREZ 

Attorney at Law 

2018 156th Avenue NE Suite 100 

Bellevue, WA 98007 

(425) 748-5005 

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It is unreasonable to expect adequate preparation for trial before the current trial 

date of November 27, 2006. The Court further finds that the interests of the public and 

the defendants in a speedy trial in this case are outweighed by the ends of justice. 

IT IS NOW, THEREFORE, ORDERED that trial shall be continued to February 

26, 2007 and that the time between the date of this Order and the new trial date be 

excludable time under the Speedy Trial Act pursuant to Title 18, United States Code, 

Sections 3161(h)(8)(A), 3161(h)(8)(B)(i), and 3161(h)(8)(B)(ii). 

 IT IS FURTHER ORDERED that pre-trial motions shall be filed on or before 

January 26, 2007. 

 Dated this 17th day of November, 2006 

A

RICARDO S. MARTINEZ 

UNITED STATES DISTRICT JUDGE 

 

Presented by: 

 s/Robert Perez___________________ 

ROBERT PEREZ 

Washington State Bar # 36221 

California State Bar # 77730 

ATTORNEY FOR DEFENDANT 

2018 156th Avenue NE, Suite 100 

Bellevue, Washington 98007-3825 

(425) 748-5005 Voice 

(425) 748-5007 Fax 

Email: Robert@RobertPerezLaw.Com

 

Case 2:06-cr-00254-RSM Document 21 Filed 11/17/06 Page 2 of 3
Page 3 

ORDER CONTINUING TRIAL 

AND PRETRIAL MOTIONS 

DEADLINE/CHANG 

CR06-254RSM-2 

 

 

ROBERT PEREZ 

Attorney at Law 

2018 156th Avenue NE Suite 100 

Bellevue, WA 98007 

(425) 748-5005 

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(telephonically approved) _________ 

LISCA N. BORICHEWSKI 

 Washington State Bar #24300 

ASSISTANT UNITED STATES ATTORNEY 

 700 Stewart Street, Suite 5100 

 Seattle, Washington 98101 

 (206) 553-2266 Voice 

 (206) 553-0882 Fax 

 Email: Lisca.Borichewski@USDOJ.gov

Case 2:06-cr-00254-RSM Document 21 Filed 11/17/06 Page 3 of 3