Free Motion to Continue Trial - 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, MOTION TO CONTINUE Plaintiff, vs. JESUS SILVERIO JAQUEZ-DIAZ (Assigned to the Honorable Paul Rosenblatt)

Defendant.

COMES NOW the Defendant, Jesus Silverio Jaquez-Diaz, by and through undersigned counsel, and respectfully moves to continue the currently scheduled trial set for April 3, 2006 at 9:00 a.m. for approximately 90 days for the following reason: A critical defense witness is currently in federal custody back East and will be transferred closer to Arizona sometime in April. The defense needs this witness to be ready for trial and can't secure his attendance prior to the currently

Case 2:04-cr-00021-PGR

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scheduled trial date. The defense recognizes that if this matter is set on June 27, 2006, a date picked out by both the defense and prosecution, that it would be beyond the current speedy trial deadline and the Defendant agrees to waive any applicable time in order to ensure the attendance of this witness. The assigned prosecutor has no objection to the continuance. It is anticipated that there will be excludable delay under 18 U.S.C. §3161(h)(8)(B)(iv). DATED this 27th day of March , 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 ORIGINAL of the foregoing pleading was e-filed this 27th day of March, 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/Pillar Abercrombie

Case 2:04-cr-00021-PGR

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Case 2:04-cr-00021-PGR

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Filed 03/27/2006

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Case 2:04-cr-00021-PGR

Document 62

Filed 03/27/2006

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