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UNITED STATES DISTRICT COURT 

DISTRICT OF ARIZONA 

United States of America, 

 Plaintiff,

 v. 

Douglas Haig, 

 Defendant.

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NO. 18-mj-00105-MHB

DEFENDANT’S UNOPPOSED 

MOTION TO CONTINUE APRIL 16, 

2018 STATUS HEARING 

Defendant, Douglas Haig, by and through undersigned counsel, respectfully requests 

this Court continue the Status Hearing currently scheduled for April 16, 2018 at 11:00 am for 

thirty (30) days. 

The parties are awaiting the results of further forensic examinations and reports, which 

bear great significance to the future hearings scheduled in this case, and the potential for a preindictment resolution. The Government informs counsel that supplemental testing has been 

conducted and those results are not yet available. Furthermore, after these reports are received, 

the parties will require additional time to prepare for the scheduled hearing or conclude a preindictment resolution. 

ATTORNEYS FOR FREEDOM LAW FIRM 

3185 S. Price Road 

Chandler, Arizona 85248 

Telephone: (480) 755-7110 

Fax: (480) 857-0150 

Marc J. Victor – SBN 016064 

Marc@AttorneysForFreedom.com 

Attorney for Defendant

Case 2:18-mj-00105-MHB Document 18 Filed 04/12/18 Page 1 of 3
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Undersigned counsel has contacted counsel for the Government, Mr. Patrick Burns, and 

he supports this request and has no objection. 

The Defendant is aware of the relief sought herein, is in full agreement with same, and 

waives time under 18 U.S.C. Section 3142 in order to reschedule this matter. 

This Motion is made in good faith and not for purposes of delay. The ends of justice 

served by granting this motion outweigh the best interests of the public and the Defendant in a 

speedy trial. 

Undersigned counsel expects that excludable delay under Title 18 U.S.C. Section 

3161(h)(7)(A) and 3161(h)(7)(B)(i) may occur as a result of the motion or from an order based 

thereon. 

THEREFORE, Defendant respectfully requests this Court continue the Status Hearing 

currently scheduled for April 16, 2018 at 11:00 am for thirty (30) days. Undersigned counsel 

proposes the Status Hearing be continued to May 16, 2018 in the morning. 

RESPECTFULLY SUBMITTED this 12th day of April, 2018. 

ATTORNEYS FOR FREEDOM LAW FIRM 

By: Marc J. Victor

 Marc J. Victor 

 Attorney for Defendant

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CERTIFICATE OF SERVICE

I hereby certify that on April 12, 2018, I filed the Original with the Clerk of the Court 

using the CM/ECF System for filing and transmittal of a Notice of Electronic Filing to the 

following CM/CEF registrants:

Kristen Brook, Esq.

Emailed to chambers:

HONORABLE MICHELLE H. BURNS

United States District Court

Sandra Day O’Connor U.S. Courthouse, Suite 323

401 West Washington Street, SPC 12

Phoenix, AZ 85003-2120

burns_chambers@azd.uscourts.gov

Copy emailed to:

Patrick Burns, Esq.

/s/ Monica Soto 

Case 2:18-mj-00105-MHB Document 18 Filed 04/12/18 Page 3 of 3