Free Motion to Continue - District Court of Arizona - Arizona

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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 HEARING

Defendant DANIEL SAMANIEGO-CACHON, by and through undersigned counsel, hereby requests the Court continue the hearing currently set for December 10, 2007, for a period of approximately 30 days and for an extension of time within which to file motions. Assistant U.S. Attorney Lisa Jennis Settel has no objection to this request. More time is necessary for the Defendant to become stabilized on his prescribed medication prior to a new competency evaluation. 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 hearing. 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 hearing for a period of approximately 30 days and extend the time for filing motions. Dated: November 29, 2007. /s/ Michael S. Reeves MICHAEL S. REEVES, Attorney for Defendant

Case 2:03-cr-01097-ROS

Document 216

Filed 11/29/2007

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CERTIFICATE OF SERVICE I hereby certify that on this date, November 29, 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

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Case 2:03-cr-01097-ROS

Document 216

Filed 11/29/2007

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