Free Motion to Continue Trial - District Court of Arizona - Arizona

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

MICHAEL S. REEVES, ESQ. State Bar Number: 010420 1212 East Osborn Phoenix, Arizona 85014 Tel: [602] 604-7577 Fax: [602] 604-7555 Attorney for Defendant UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA UNITED STATES OF AMERICA, Plaintiff, Vs. DANIEL SAMANIEGO-CACHON, Defendant. ) ) ) ) ) ) ) ) ) ) ) NO. CR03-01097-003-PHX-ROS MOTION TO CONTINUE TRIAL AND EXTEND TIME TO FILE MOTIONS (12th)

Defendant DANIEL SAMANIEGO-CACHON, by and through undersigned counsel, hereby requests the Court continue the trial currently set for February 5, 2008, for a period of approximately 60 days, and for an extension of time within which to file motions. Counsel for Defendant is in the process of looking to hire additional mental health experts to assist in the evaluation process. Assistant U.S. Attorney Lisa Jennis Settel has no objection to this request. This motion is made in good faith and not for purposes of delay. The interests of justice served by a continuance outweigh the interests of the Defendant and the public in a speedy trial. Excludable delay under 18 U.S.C. §3161(h) will occur as a result of this motion or from an order based thereon. WHEREFORE, it is requested that the Court continue the trial date for a period of approximately 60 days and extend the time for filing motions. Dated: December 10, 2007. /s/ Michael S. Reeves MICHAEL S. REEVES, Attorney for Defendant SAMANIEGO-CACHON

Case 2:03-cr-01097-ROS

Document 220

Filed 12/10/2007

Page 1 of 2

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

CERTIFICATE OF SERVICE I hereby certify that on this date, December 10, 2007, I electronically transmitted the attached document to the Clerk's Office using the CM/ECF System for filing and transmittal of Notice of Electronic Filing to the following CM/ECT registrants: Lisa Jennis Settel, Assistant U.S. Attorney by: /s/ Michael S. Reeves

2

Case 2:03-cr-01097-ROS

Document 220

Filed 12/10/2007

Page 2 of 2