Free Motion to Continue - District Court of Arizona - Arizona

Rena P. Glitsos
45 W. Jefferson, Suite 512 Phoenix, AZ 85003 (602) 528-0882 AZ State Bar No. 013009 Attorney for Defendant [email protected] IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA

________________________________________ ) ) UNITED STATES OF AMERICA ) ) Plaintiff, ) ) v. ) ) FERNANDO WHITE, ) Defendant. ) ) _______________________________________ )

No. CR 04-657-PHX-NVW MOTION TO CONTINUE TRIAL AND TO EXTEND DEADLINE FOR MOTIONS (First Trial Setting With Undersigned Counsel)

Defendant, through undersigned counsel, respectfully moves the Court to continue trial for 60 days from the current setting of September 6, 2005 for the following reasons: Defendant was originally assigned to undersigned counsel for sentencing purposes, previous counsel having withdrawn. At the sentencing hearing, defendant withdrew from the plea agreement and the matter got set for trial on September 6, 2005. Undersigned counsel needs additional time to prepare for trial as she has been in trial all summer and has only recently received this case. Counsel has discussed this motion with AUSA Sharon Sexton and she has no objection. In light of the above, defendant respectfully moves the Court to continue the trial for 60 days and to extend the deadline for filing pretrial motions accordingly. The ends of justice served by the granting of this motion outweigh the best interests of the public and the defendant in a speedy trial. Excludable delay under 18 U.S.C. Section 3161(h) may occur as a result of this motion or from any attendant orders.

Case 2:04-cr-00657-NVW

Document 41

Filed 09/08/2005

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RESPECTFULLY SUBMITTED this 8st day of September, 2005

By_/s/ Rena P. Glitsos Rena P. Glitsos Copy of the foregoing was emailed/mailed/delivered this 8st day of September, 2005 to: The Honorable Neil V. Wake United States District Court Judge 401 W. Washington Phoenix, AZ 85003 Copy of the foregoing was mailed to: Sharon Sexton Assistant United States Attorney Two Renaissance Square 40 N. Central Phoenix, AZ 85004

By /s/ Rena P. Glitsos

Rena P. Glitsos

Case 2:04-cr-00657-NVW

Document 41

Filed 09/08/2005

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