SUPER! AVAPAI EP MARK BRNOVICH : Attorney General Wi HOV 13 AM IO 10 Firm Bar No. 14000 BLAINE D. GADOW ae Assistant Attomey General oy, KMADDEN State Bar No. 013741 By 2005 N. Central Ave Phoenix, Arizona 85004-1592 Telephone: 602-542-3881 ermiraud@azag. gov Attorneys for Plaintiff IN THE SUPERIOR COURT OF THE STATE OF ARIZONA IN AND FOR THE COUNTY OF YAVAPAI STATE OF ARIZONA, Cause No.: P1300CR201801308 Plaintiff, STATE’S MOTION TO DISMISS vs. WITHOUT PREJUDICE THOMAS JOHN CHANTRY, Defendant. The State of Arizona, by and through undersigned counsel, moves this Court to issue at | $Assianed tothe Honorable Nepper, Div. Order consistent with the attached Proposed Order dismissing this case without prejudice. Thd State makes this motion not to avoid any applicable Rule 8 time limits, but rather because dismissal of this case will best serve the interests of justice when viewed in the totality of circumstances. ‘After lengthy communication and discussion with the listed victim in this matter pursuant t A.RS.§13-4419 and Article 2, Section 2 (6) and (10) of the Arizona Constitution, and with dud consideration of the judicial and prosecutorial resources involved in continuing this particulay prosecution, and with all factors considered in light of the defendant's conviction and sentence int P1300CR201600966, the State and the victim are convinced that dismissal of this prosecution willSot ost oe ay 12 13 4 15 16 7 18 19 20 21 22 23 4 26 best serve the interests of justice and the victim’s interests as well. ‘The listed victim supports thi request in direct communication with the undersigned and the investigating case agent. For those reasons, the State moves to dismiss this case without prejudice as of the date thd Order is signed by this Court. The undersigned avows that he has consulted with defense counsel for Thomas Chantry about this motion, and there is no defense objection to this motion. RESPECTFULLY SUBMITTED this. am day of November, 2019. ‘Assistant Attorney General Criminal Division ORIGINAL of the foregoing filed this_|7¥¢day of November, 2019. COPY of the foregoing mailed this (7° day of November, 2019, to: ‘The Honorable John Napper Yavapai County Superior Court 120 South Cortez Street Prescott, Arizona 86303 COP Yip the foregoing e-mailed this [2 day of November, 2019, to: Ryan Stevens Griffen & Stevens Law Firm, PLLC 609 N. Humphreys St, Flagstaff, AZ 86001-3023 stevens @flagstaff-lawyer.com office@ flagstaff-lawyer.com Gude | (001) rr PSS