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Gregory J. Kuykendall, Bar # 012508

Amy P. Knight, Bar # 031374

KUYKENDALL & ASSOCIATES

531 S Convent Avenue

Tucson, AZ 85701

(520) 792-8033

greg@kuykendall-law.com

amyknight@kuykendall-law.com

Attorneys for Defendant Scott Daniel Warren

UNITED STATES DISTRICT COURT

DISTRICT OF ARIZONA

United States of America,

Plaintiff,

vs.

SCOTT DANIEL WARREN,

Defendant.

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No.CR-18-00223-001-TUC-RCC

UNOPPOSED MOTION TO 

CONTINUE TRIAL

It is expected that excludable delay under Title 18 U.S.C. Section 

3161(h)(7)(A) may occur as a result of this motion or of an order based thereon.

Defendant, Scott Daniel Warren, by and through his pro bono attorneys

Gregory J. Kuykendall and Amy P. Knight, respectfully requests that this Court 

vacate the January 8, 2019 trial date. Defendant requests that the Court convene a 

scheduling conference in conjunction with the currently scheduled motion hearing 

on January 14, 2019 to select a new trial date. 

Case 4:18-cr-00223-RCC-DTF Document 147 Filed 12/20/18 Page 1 of 3
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This proposed continuance is being requested because significant issues 

remain to be resolved before a trial can be conducted in this case. At this Court 

knows, substantive motions remain pending, including a motion to suppress key 

evidence (fully briefed since September 4, 2018), a motion to reconsider denial of 

the motion to dismiss under the Religious Freedom Restoration Act (filed 

September 26, 2018), and a motion to dismiss based on international law (fully 

briefed since December 12, 2018). In addition, the defense has recently asked this 

Court to reconsider an order entered by the Magistrate Judge concerning discovery 

on a selective enforcement claim, and this Court has set that motion for hearing on 

January 14, 2019—after the current trial date. Whatever the outcome of that 

motion, the defense will still require time to file appropriate substantive motions 

based on the Government’s disclosure regarding selective enforcement. 

Counsel for the Government have been consulted and have no objection to 

this motion. Undersigned counsel avows that this request for a continuance has not 

been made for purposes of harassment or delay.

RESPECTFULLY SUBMITTED this 20th day of December, 2018.

By /s/ Amy P. Knight

Gregory J. Kuykendall

Amy P. Knight

531 S Convent Avenue

Tucson, AZ 85701

Attorneys for Defendant Scott 

Daniel Warren

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CERTIFICATE OF SERVICE

I certify that on December 20th, 2018, I electronically transmitted a PDF 

version of this document to the Clerk of Court using the CM/ECF System for filing 

and for transmittal of a Notice of Electronic Filing to the following CM/ECF 

registrants: 

Nathaniel J. Walters, Esq. (email: Nathaniel.walters@usdoj.gov) 

Anna R. Wright, Esq. (email: anna.wright@usdoj.gov) 

United States Attorney’s Office 

405 W. Congress, Suite 4800 

Tucson, AZ 85701

Case 4:18-cr-00223-RCC-DTF Document 147 Filed 12/20/18 Page 3 of 3