STIPULATED MOTION AND ORDER 

CONTINUING TRIAL DATE AND 

PRETRIAL MOTION CUTOFF 

Page 1 of 5 

CR06-0107JCC (Neal) 

ANNA M. TOLIN 

Attorney at Law 

2001 Western Avenue, Suite 200 

Seattle, WA 98121 

(206) 812-5850 

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Honorable John C. Coughenour 

UNITED STATES DISTRICT COURT 

WESTERN DISTRICT OF WASHINGTON 

SEATTLE 

UNITED STATES OF AMERICA, 

 Plaintiff, 

 vs. 

CHRISTOPHER J. NEAL, 

 Defendants. 

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No. CR06-0107JCC 

STIPULATED MOTION AND ORDER 

CONTINUING TRIAL DATE AND 

PRETRIAL MOTIONS CUTOFF 

STIPULATION

The United States, by and through John J. Lulejian, Assistant United States 

Attorney, and defendant Christopher J. Neal, by and through his attorney, Anna M. 

Tolin, hereby stipulate and agree that good cause exists to continue trial in this case 

from July 24, 2006 to October 30, 2006, and to extend the pretrial motions date cutoff to 

October 2, 2006. 

The parties agree that this continuance is necessary for the reasons explained 

herein. Defendant has been charged with possession of cocaine with intent to deliver. 

The case is based on evidence and allegations developed by local law enforcement 

officers. To date, despite the parties’ best efforts, the ability to obtain certain 

Case 2:06-cr-00107-JCC Document 19 Filed 07/14/06 Page 1 of 4
STIPULATED MOTION AND ORDER 

CONTINUING TRIAL DATE AND 

PRETRIAL MOTION CUTOFF 

Page 2 of 5 

CR06-0107JCC (Neal) 

ANNA M. TOLIN 

Attorney at Law 

2001 Western Avenue, Suite 200 

Seattle, WA 98121 

(206) 812-5850 

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information from state agencies has caused delays in the discovery process. Further 

time is needed by the parties to continue to investigate and research complex legal 

issues with regard to the admissibility of evidence and multiple sentencing and criminal 

history issues. The parties also actively have been attempting to negotiate a resolution 

to this case. These efforts have been complicated by related state and federal cases 

involving Defendant that will impact any plea agreement entered in this case. 

Additional time is needed to fully assess these matters before the parties can formalize 

a plea agreement or adequately prepare for trial in this case. 

Defendant has been advised of his right to a speedy trial and has agreed to 

waive this right through October 30, 2006; a signed waiver of speedy trial will be filed 

with the Court. 

 The parties believe that the ends of justice to be served by granting a 

continuance of the trial date outweighs the best interests of the public and Defendant in 

a speedy trial. 

Respectfully submitted this 7th day of July, 2006. 

___/s/___________________________ 

 John Lulejian 

 Assistant United States Attorney 

 700 Stewart Street, Suite 5220 

 Seattle, WA 98101 

 Telephone: (206) 553-7970 

 Facsimile: (206) 553-4440 

 E-mail: john.lulejian@usdoj.gov 

____/s/_________________________________

Anna M. Tolin, WSBA #22071 

 Attorney for Christopher Neal 

 Market Place Two, Suite 200 

 2001 Western Avenue 

 Seattle, WA 98121 

 Telephone: (206) 812-5850 

 Facsimile: 

 E-mail: anna@annatolin.com

Case 2:06-cr-00107-JCC Document 19 Filed 07/14/06 Page 2 of 4
STIPULATED MOTION AND ORDER 

CONTINUING TRIAL DATE AND 

PRETRIAL MOTION CUTOFF 

Page 3 of 5 

CR06-0107JCC (Neal) 

ANNA M. TOLIN 

Attorney at Law 

2001 Western Avenue, Suite 200 

Seattle, WA 98121 

(206) 812-5850 

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ORDER

 Based upon the foregoing stipulation of the parties, and upon all of the papers 

and proceedings previously filed herein, the Court makes the following FINDINGS OF 

FACT: 

 The parties require additional time to investigate and research complex factual 

and legal issues in this case; 

 Discovery is ongoing and the parties are actively engaged in efforts to continue 

trial preparations and explore possible resolutions to this case; 

 Despite the parties’ due diligence, additional time is needed to ensure effective 

assistance of counsel; 

In view of the parties' agreement to continue the trial date, for the reasons stated 

above, Defendant's knowing, voluntary, and intelligent waiver of his right to a speedy 

trial, and the interest of the public in ensuring the accused adequate, effective, and 

continued representation by counsel presently assigned, this Court finds that the ends 

of justice served by granting a continuance outweigh the best interest of the public and 

Defendant in a speedy trial. 

 Accordingly, the parties' motion for continuance is HEREBY GRANTED. Trial is 

reset for October 30, 2006. The pre-trial motions cutoff date is continued until 

October 2, 2006. The time from the filing of the stipulated motion through the new trial 

date shall be excludable under the Speedy Trial Act, Title 18, United States Code, 

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

 DATED this 14th day of July, 2006. 

 

 JOHN C. COUGHENOUR 

 UNITED STAT

A

ES DISTRICT JUDGE 

Case 2:06-cr-00107-JCC Document 19 Filed 07/14/06 Page 3 of 4
STIPULATED MOTION AND ORDER 

CONTINUING TRIAL DATE AND 

PRETRIAL MOTION CUTOFF 

Page 4 of 5 

CR06-0107JCC (Neal) 

ANNA M. TOLIN 

Attorney at Law 

2001 Western Avenue, Suite 200 

Seattle, WA 98121 

(206) 812-5850 

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/ / / 

Presented by: 

___/s/_________________________ 

John J. Lulejian 

Assistant United States Attorney 

____/s/________________________

Anna M. Tolin, WSBA #22071 

Attorney for Christopher Neal 

 

Case 2:06-cr-00107-JCC Document 19 Filed 07/14/06 Page 4 of 4