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

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MARK PAIGE 45 West Jefferson Luhrs Tower - Suite #806 Phoenix, AZ 85003-2317 (602) 254-5457 State Bar #020902 [email protected] Attorney for Defendant

UNITED STATES DISTRICT COURT 7 8 9 10 11 12 13 14 The defendant, Goran Bencun, by and through counsel respectfully moves the Court for 15 a continuance of the presently set trial date of March 29, 2006 and extension of the deadline for 16 pretrial motions on the following grounds: 17 1. The defendant is charged by Indictment with perjury and false statement on an 18 immigration document. The defendant was Indicted on or about December 15, 2004 and 19 arraigned on December 20, 2004. 20 2. Counsel has a conflict with another CR-05-0014-PHX-EHC. This matter is set for a 21 suppression hearing and settlement conference on March 28, 2006 and trial to begin on 22 March 30, 2006. This matter is charged as a first degree murder. 23 3. Counsel for the defendant is continues to attempt to investigate this matter. Counsel 24 is attempting to obtain records from the IOM relating to the processing of this defendant. 25 4. This defendant is in custody. 26 Counsel for the Government, Andrew Pacheco, has no objection to this request. 27 The defendant respectfully requests a continuance of this matter for no more than thirty 28 DISTRICT OF ARIZONA _______________________________________ ) UNITED STATES, ) No.: CR-04-1280-PHX-FJM ) Plaintiff, ) ) DEFENDANT'S MOTION TO v. ) CONTINUE TRIAL AND EXTEND ) PRETRIAL MOTIONS AND ALL Goran Bencun, ) OTHER DEADLINES ) Defendant. ) (Seventh Request) _______________________________________)

Case 2:04-cr-01280-FJM

Document 36

Filed 03/15/2006

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(30) days to allow undersigned counsel to be prepared and able to render effective assistance of counsel consistent with the Sixth Amendment guarantee for every defendant.

Respectfully submitted this 15 th day of March, 2006. S/ Mark A. Paige MARK PAIGE Attorney for Defendant Copy of the foregoing was electronically delivered this 15 th day of March , 2006 to: Andrew Pacheco Assistant U.S. Attorney Two Renaissance Square 40 N. Central Avenue Suite 1200 Phoenix, AZ 85004-4408 s/ Mark A. Paige Mark A. Paige

Case 2:04-cr-01280-FJM

Document 36

Filed 03/15/2006

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