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 starting on January 4, 2006 that is expected to last approximately 4 days. Thereafter, undersigned counsel starts a first degree murder case which is currently set for January 9, 2006 but is

Case 2:04-cr-00021-PGR

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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. DATED this 15 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 15 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 Mr. Glenn McComick Assistant United States Attorney 40 North Central - Suite 1200 Phoenix, Az 85004 By: s/Andrew V. Jackson

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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. (Assigned to the Honorable RosenBlatt) Jesus Silverio Jaquez-Diaz, Defendant. O R D E R ON MOTION TO CONTINUE TRIAL

COMES NOW the Defendant, Jesus Silverio Jaquez-Diaz, by and through undersigned counsel, and good cause shown, IT IS HEREBY OREDERED continuing the trial in the above-entitled case from the 10 th day of January, 2006, to the ___ day of ____________, 2006, at ____________a.m. For the reasons set forth in the Motion, to wit: counsel for the Defendant has a trial conflict

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IT IS FURTHER ORDERED extending the time for filing pretrial motions to the ___ day of _____________, 2005. EXCLUDABLE DELAY under 18 U.S.C. §3161(h)(8)(B)(iv) is found to commence on the ___ day of _______________, 2005, for a period of ____________ days. DATED THIS _____ day of __________________________, 2005.

_____________________________________ The Honorable U.S. District Judge RosenBlatt

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