Free Motion to Continue - 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 January 10, 2005 at 9:00 a.m. for approximately 30 days for the following reason: Undersigned counsel will be in a felony assault trial State v. Osborne CR2005-105747-001DT starting on January 4, 2006 that is expected to last approximately 4 days. Thereafter, undersigned counsel starts a first degree murder

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case State v. Karr CR 2005-014563-001 DT which is currently set for January 9, 2006 but is expected to ride the calender until the conclusion of the assault case. The first degree murder case is far older than the Jacquez case and involves as in custody defendant. The assigned prosecutor has no objections to the continuance because of defense counsels trial conflict. It is anticipated that excludable delay may occur pursuant to 18 U.S.C. §3161(h)(8)(B)(iv) as a result of this motion or an order based thereon. DATED this 20 th day of December, 2005. 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 20 th day of December, 2005, 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

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Mr. Glenn McComick Assistant United States Attorney 40 North Central - Suite 1200 Phoenix, Az 85004 By: s/Andrew V. Jackson

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