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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 STATUS 

HEARING 

*Expedited Consideration Requested*

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

this Court continue the Status Hearing currently scheduled for July 24, 2018 at 9:30 am for 

thirty (30) days. 

Undersigned counsel has been informed Counsel for the Government will be out of 

State in training on July 24, 2018 and shortly after starting a Trial on July 30, 2018. The 

parties received initial results of further forensic examinations and reports, which bear great 

significance to the future hearings scheduled in this case, and the potential for a 

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 26 Filed 07/23/18 Page 1 of 4
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pre-indictment resolution. Additional time is needed in order to review these reports and 

confer with defense’s expert. The parties expect this to be the last request for a continuance 

in this matter. 

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 July 24, 2018 at 9:30 am for thirty (30) days. Undersigned counsel 

proposes the Status Hearing be continued to August 28, 2018 in the morning after 10:00 

am.

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 RESPECTFULLY SUBMITTED this 23rd day of July, 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 July 23, 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 DEBORAH M. FINE

United States District Court

123 North San Francisco Street, Suite 200

Flagstaff, AZ 86001

fine_chambers@azd.uscourts.gov

Copy emailed to:

Patrick Burns, Esq.

John.P.Burns@usdoj.gov

/s/ Andrea Yirak 

Case 2:18-mj-00105-MHB Document 26 Filed 07/23/18 Page 4 of 4