Defendant’s Motion for Continuance of Trial — No. 5:20-cr-04066 (Dkt. 29, N.D. Iowa)

Summary

A defendant's unresisted motion for continuance of trial filed in the U.S. District Court for the Northern District of Iowa, Western Division, in United States v. Donald Franklin Trosin, No. CR20-4066-LTS-KEM, docketed as 5:20-cr-04066, as Document 29 of 2 pages. Counsel states that Trosin's trial is scheduled for November 2, 2020 with no prior continuances, that he would benefit from a continuance to review discovery, discuss strategy and plea options, engage in plea negotiations and prepare for any trial, and that AUSA Vavricek does not resist. Trosin asks the Court for a continuance to the December 2020 trial setting. The motion is signed by Tim Herschberger of the Federal Defender's Office, with a certificate of service dated October 7, 2020.

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                   IN THE UNITED STATES DISTRICT COURT
                    FOR THE NORTHERN DISTRICT OF IOWA
                             WESTERN DIVISION


UNITED STATES OF AMERICA,                  )
                                           )
                      Plaintiff,           )    No. CR20-4066-LTS-KEM
                                           )
v.                                         )
                                           )
                                           )    DEFENDANT’S MOTION FOR
DONALD FRANKLIN TROSIN,                    )    CONTINUANCE OF TRIAL
                                           )    (UNRESISTED)
                      Defendant.           )
                                           )


         COMES NOW, Defendant Donald Franklin Trosin, to move to continue his

trial. In support, counsel states:

         1.    The trial for Mr. Trosin is scheduled for November 2, 2020. There have

not been any prior continuances.

         2.    Mr. Trosin would benefit from a trial continuance to review discovery,

discuss strategy and plea options, engage in plea negotiations, and prepare for any

trial.

         3.    AUSA Vavricek does not resist this motion.

         WHEREFORE, Mr. Trosin asks the Court for a continuance to the December

2020 trial setting.




         Case 5:20-cr-04066-LTS-KEM Document 29 Filed 10/07/20 Page 1 of 2
                                                           Respectfully submitted,

                                                           FEDERAL DEFENDER’S OFFICE
                                                           701 Pierce Street, Suite 400
                                                           Sioux City, Iowa 51101
                                                           Telephone: 712-252-4158
                                                           E-mail: Timothy_Herschberger@fd.org

                                                           By: /s/ Tim Herschberger
                                                           TIM HERSCHBERGER
                                                           ATTORNEY FOR DEFENDANT

                       CERTIFICATE OF SERVICE
I hereby certify that on October 7, 2020, I filed this document via ECF,
which will serve notice of its filing to AUSA Vavricek.

                             /s/ Geralynn Fjeldheim




                                                               2




         Case 5:20-cr-04066-LTS-KEM Document 29 Filed 10/07/20 Page 2 of 2


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