Free Settlement Conference - District Court of Arizona - Arizona

Daniel R. Raynak
State Bar No. 10098 45 West Jefferson, Suite 225 Phoenix, Arizona 85003 telephone (602) 992-7776 facsimile (602) 992-7646 Attorney for Defendant IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA Case No.: CR04-0021-PHX-PGR United States of America, Plaintiff, vs. Jesus Silverio Jacques-Diaz, (Assigned to the Honorable Paul Rosenblatt) REQUEST FOR SETTLEMENT CONFERENCE

Defendant. The Defendant, by and through undersigned counsel, respectfully request that the Court set this matter for a settlement conference to allow Mr. Jessie Jacquez the opportunity to understand more fully the potential exposure he faces as a consequence of the charge in this case and to evaluate the Government's offer. It is requested that the United States Probation Department prepare a criminal settlement conference report. The Defendant requests a settlement conference be scheduled as soon as possible. It should be noted that undersigned counsel will be on vacation from

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July 22 though August 6, 2006. Thereafter, undersigned counsel continues with an ongoing death penalty on August 7, 2006 and therefore requests that the settlement conference either be set on or before July 21, 2006, or sometime after August 6, in the mornings only as undersigned counsel will be in trial in the afternoons, starting August 7, 2006. Assistant U.S. Attorney, Glenn McCormick, does not object to the request. It is not expected that excludable delay under Title 18 U.S.C. Section 3161(h)(1)(F) may occur as a result of this motion or from as order based thereon. RESPECTFULLY SUBMITTED this 28th day of June, 2006

DANIEL R. RAYNAK, P.C.

By: s/Daniel R. Raynak Daniel R. Raynak, Esq. 45 Jefferson Street, Suite 225 Phoenix, Arizona 85003 Attorney for Defendant

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ORIGINAL of the foregoing pleading was e-filed this 28th day of June, 2006, with: Clerk of the Court United States District Court Sandra Day O'Connor U.S. Courthouse 401 W. Washington Street Phoenix, Arizona 85003 Attention Honorable Paul Rosenblatt Mr. Glenn McCormick Assistant United States Attorney 40 North Central - Suite 1200 Phoenix, Az 85004 By: s/Pilar Abercrombie

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