Motion for Continuance — United States v. Douglas S. Ward (Western District of Missouri, Document 33)

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Motion for Continuance in the United States District Court for the Western District of Missouri, Southern Division, Criminal Action No. 21-CR-05003, United States of America v. defendant Ward. Defendant Ward, through the attorney of record, requests a continuance of the jury trial setting, stating that the matter is scheduled for pretrial conference on April 06, 2021 and jury trial for the week of May 3rd, 2021. It states that defense counsel requires additional time for the discovery process and that the Government by AUSA Jessica Sarff does not oppose a continuance. The motion asks the Court to reset the matter to the August or September trial docket due to older cases that counsel has already set.

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                  IN THE UNITED STATES DISTRICT COURT FOR THE
                         WESTERN DISTRICT OF MISSOURI,
                               SOUTHERN DIVISION


UNITED STATES OF AMERICA,                               )
                                                        )
                                Plaintiff,              )
                                                        )
       vs.                                              )               Criminal Action No.
                                                        )               21-CR-05003
                                                        )
DOUGLAS S. WARD                                         )
                                                        )
                                Defendant.              )

                                 MOTION FOR CONTINUANCE

       COMES NOW Defendant Douglas S. Ward, by and through his attorney of record,

Stuart P. Huffman, and requests a continuance of the jury trial setting in the above-styled cause.

In support thereof, the Defendant submits the following sworn facts:

       1.       The above matter is scheduled for pretrial conference on April 06, 2021 and jury

                trial for the week of May 3rd, 2021

       2.       Defense counsel requires additional time for the discovery process.

       3.       The Government by AUSA Jessica Sarff does not oppose a continuance.

       4.       That a continuance was discussed with Defendant Ward who understands the

                need for additional time and that it is in his best interests.

       5.       This continuance is not sought for the purpose of dilatory delay, but is sought in

                truth and fact so that Defendant may be afforded due process of law under the

                Fifth Amendment to the United States Constitution.




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            Case 3:21-cr-05003-MDH Document 33 Filed 04/02/21 Page 1 of 2
       WHEREFORE, Defendant respectfully requests this Court to remove this case from its

scheduled trial date and reset the matter to the August or September trial docket due to older

cases that Counsel has already set.

                                                     WHITEAKER & WILSON, P.C.


                                                     By /s/ Stuart P. Huffman__
                                                     Stuart P. Huffman
                                                     Missouri Bar No. 49633
                                                     Attorney for Defendant


                                CERTIFICATE OF SERVICE

        I hereby certify that on April 2, 2021, I electronically filed the foregoing with the Clerk
of the Court using the CM/ECF system which sent notification of such filing to the United States
Attorney and all other CM/ECF participants in this case.



                                                     By /s/ Stuart P. Huffman__
                                                     Stuart P. Huffman
                                                     Missouri Bar No. 49633
                                                     Attorney for Defendant

                                                     3315 E. Ridgeview St, Suite 4000
                                                     Post Office Box 3758
                                                     Springfield, MO 65808-3758
                                                     Telephone: (417) 882-7400
                                                     Facsimile: (417) 882-6101




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         Case 3:21-cr-05003-MDH Document 33 Filed 04/02/21 Page 2 of 2


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