Free Motion to Continue - District Court of Arizona - Arizona

1 JON M. SANDS Federal Public Defender 2 District of Arizona 3 850 W. Adams, Suite 201 Phoenix, Arizona 85007 4 Telephone: (602) 382-2721 Facsimile: (602) 382-2800 5 JEANETTE E. ALVARADO, #016111 6 Asst. Federal Public Defender 7 Attorney for Defendant [email protected] 8 IN THE UNITED STATES DISTRICT COURT 9 DISTRICT OF ARIZONA 10 11 12 13 14 15 16 17 18 19 vs. (First Request) Pascual Ruiz-Lazaro, Defendant. Pascual Ruiz-Lazaro, through undersigned counsel, moves to continue the admit/deny hearing presently scheduled for October 2, 2006, for a period of at United States of America, Plaintiff, No. CR-01-190-PHX-JAT MOTION TO CONTINUE ADMIT/DENY HEARING

20 least thirty (30) days. The reason for the requested continuance is that Mr. Ruiz21 Lazaro is currently facing supervised release revocation proceedings arising from an 22 alleged re-entry on May 17, 2006. Undersigned counsel has spoken with assigned 23 Assistant U.S. Attorney Lisa Settle, who states that the government has requested the 24 25 26 whether the government will charge Mr. Ruiz-Lazaro with a new charge of illegal re27 entry. It is in Mr. Ruiz-Lazaro's interest to be advised as to whether the government 28 will indeed charge him with a new felony offense, and attempt to resolve both the new potential charge, and the matter in this supervised release case, together. original "A" (Alien) file for Mr. Ruiz-Lazaro to make the final determination as to

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1 Therefore, a continuance of thirty (30) days of his current admit/deny date is 2 requested. 3 4 5 6 8 9 10 11 12 13

Assistant U.S. Attorney, Lisa Settel, has been contacted regarding the

requested continuance, and she has no objection. It is expected that excludable delay under Title 18 U.S.C. §

7 3161(h)(1)(F) will occur as a result of this motion or from an order based thereon. Respectfully submitted: September 22, 2006. JON M. SANDS Federal Public Defender s/Jeanette E. Alvarado JEANETTE E. ALVARADO Asst. Federal Public Defender

14 Copy of the foregoing transmitted nd 15 by ECF this 22 day of September, 2006, to: 16 CLERK'S OFFICE 17 United States District Court 18 Sandra Day O'Connor Courthouse 401 W. Washington 19 Phoenix, Arizona 85003 20 LISA SETTEL Assistant U.S. Attorney 21 United States Attorney's Office 22 Two Renaissance Square 40 N. Central Avenue, Suite 1200 23 Phoenix, Arizona 85004-4408 24 Copy mailed to: 25 PASCUAL RUIZ-LAZARO 26 Defendant s/Gabrielle M. Dorsey 27
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