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

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BALTAZAR INIGUEZ Attorney at Law 3106 N. 16th Street Phoenix, AZ 85016-7610 Phone (602) 285-5688 Fax (602) 277-1636 [email protected] State Bar No. 006084 Attorney for Defendant UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA United States of America, Plaintiff, vs. Cameron Braxton, ) ) ) ) ) ) ) ) ) ) ) No. CR 03-421-PHX-SMM

MOTION TO CONTINUE TRIAL AND EXTEND TIME FOR FILING MOTIONS

(1ST Request)

Defendant.

COMES NOW Defendant Cameron Braxton, by and through his undersigned attorney, and respectfully requests this Court to continue the trial date set on December 5, 2006 for ninety (90) days and vacate the status conference now set on November 20, 2006 at 11:00 a.m. for the reason that voluminous discovery (over 3000 pages) needs to be re-reviewed as defendant has been on bench warrant status since January 5, 2005; counsel needs to meet with defendant when

Case 2:03-cr-00421-SMM

Document 587

Filed 11/09/2006

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said discovery has been reviewed; additional discovery may be forthcoming and additional time will be needed for trial preparation. Let the Court be advised that the Assistant U.S. Attorney does not object to a continuance in this matter. It is expected excludable delay under Title 18 U.S.C. Section 3161 (h)(8)(A) may occur as a result of this Motion or from an Order based thereon. RESPECTFULLY SUBMITTED this 9th of November, 2006.

s/Baltazar Iniguez BALTAZAR INIGUEZ Attorney for Defendant Cameron Braxton CERTIFICATE OF SERVICE

I hereby certify that on this date, I electronically transmitted the attached documents to the Clerk's Office using the CM/ECF System for filing and 19 transmittal of Notice of Electronic filing to the following CM/ECF registrants: 20 Keith Vercauteren.
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Case 2:03-cr-00421-SMM

Document 587

Filed 11/09/2006

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