Free Motion to Continue Change of Plea Hearing - District Court of Arizona - Arizona

Rena P. Glitsos, AZ Bar No. 013009 Law Office of Rena P. Glitsos 45 W. Jefferson, Suite 512 Phoenix, AZ 85003 [email protected]

UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA United States of America, Plaintiff, v. Alfredo Reyes-Arista, Defendant. CR 04-0657-PHX-NVW Defendant's Motion to Continue Change of Plea

Defendant, through undersigned counsel, respectfully moves the Court to continue the change of plea currently set in the above referenced matter. Defense counsel has been in trial in State v. Hargrave, CR 2002-009759, a capital case in Maricopa County Superior Court for four weeks and the eligibility phase of trial is still ongoing. As a result, counsel has not been able to meet with defendant and a court interpreter to go over the plea agreement and will most likely be in court at the time the plea is scheduled for on February 14, 2006.

Case 2:04-cr-00657-NVW

Document 52

Filed 02/13/2006

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Defense counsel has attempted to contact AUSA Sharon Sexton regarding this motion but has not been successful as of the drafting of this motion. However, Ms. Sexton's assistant was able to confer with Ms. Sexton's supervisor and was able to inform defense counsel that the government had no objection. Excludable delay under 18 U.S.C.§3161(h)(8) may occur as a result of this motion and any attendant orders.

Date: February 13, 2006

/s/ Rena P. Glitsos Counsel for Defendant.

I hereby certify that on February 13, 2006, I electronically transmitted the attached document to the Clerk's Office using the CM/ECF system for filing and transmittal of Notice of Electronic Filing to the following CM/ECF registrants:

AUSA Sharon Sexton Two Renaissance Square 40 N. Central Ave., Suite 1200 Phoenix, AZ 85004

Case 2:04-cr-00657-NVW

Document 52

Filed 02/13/2006

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