Free Motion to Continue - District Court of Arizona - Arizona

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JERRY HERNANDEZ ATTORNEY AT LAW BAR #13021 115 W. HU-ESTA DR. TEMPE, AZ 85282 (480) 231-3053 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA United States of America, Plaintiff, vs. JORGE VELARDE-CASTRO, Defendant. ) ) ) ) ) ) ) ) ) ) ) ) CR 04-00213-001-PHX-DGC (Assigned to the Honorable David G. Campbell) MOTION TO CONTINUE ADMIT/DENY HEARING (Second Request)

Comes now the defendant, Jorge Velarde-Castro, and respectfully requests a continuance of his admit/deny hearing currently set for April 28, 2008.

MEMORANDUM OF POINTS AND AUTHORITIES Mr. Velarde-Castro was just indicted in CR08-0292-PHX-DGC. His arraignment date was on April 16, 2008; his current trial date is June 10, 2008.

Counsel has, by separate pleading, moved to continue Mr. Velarde-Castro's trial.

Case 2:04-cr-00213-DGC

Document 31

Filed 04/20/2008

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The basis of that continuance request is that Mr. Velarde-Castro may have a claim to citizenship.

Counsel has spoken with AUSA Karen McDonald and she does not oppose the motion to continue. Both counsel request that this hearing be continued to the date set in CR08-0292-PHX-DGC.

Respectfully submitted April 20, 2008 s/ JERRY HERNANDEZ JERRY HERNANDEZ 115 W. Hu-Esta Dr. Tempe, Arizona 85282 BAR #13021 I hereby certify that on April 20, 2008, I electronically transmitted the attached document to the Clerk's Office using the CM/ECF system for filing and transmittal of a Notice of Electronic Filing to the following CM/ECT registrants: Karen McDonald Assistant United States Attorney Copy Mailed to: Jorge Velarde-Castro Defendant

Case 2:04-cr-00213-DGC

Document 31

Filed 04/20/2008

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