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 (First Request)

Comes now the defendant, Jorge Velarde-Castro, and respectfully petitions this court to continue his admit/deny hearing.

MEMORANDUM OF POINTS AND AUTHORITIES The defendant is set for an admit/deny hearing on March 31, 2008. The allegations are that he possessed narcotic drugs and illegally re-entered the country. The U.S. Attorney's Office is currently deciding whether to indict the defendant on his new illegal re-entry charges.

Case 2:04-cr-00213-DGC

Document 27

Filed 03/27/2008

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The defendant would like to know whether new charges are pending before he makes the decision to admit or deny. If new charges are pending, he would like to take advantage of the package deal offered in supervised release illegal re-entries.

A two week continuance should be sufficient. Assistant United States Attorney Darcy Cerow has no objection to this continuance.

Respectfully submitted March 27, 2008 s/ JERRY HERNANDEZ JERRY HERNANDEZ 115 W. Hu-Esta Dr. Tempe, Arizona 85282 BAR #13021 I hereby certify that on March 27, 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: Darcy Cerow Assistant United States Attorney Copy Mailed to: Jorge Velarde-Castro Defendant

Case 2:04-cr-00213-DGC

Document 27

Filed 03/27/2008

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