1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20
JON M. SANDS Federal Public Defender ROSEMARIE VALDEZ Assistant Federal Public Defender State Bar No. 017070 407 W. Congress, Suite 501 Tucson, AZ 85701-1310 Telephone: (520) 879-7500 [email protected] Attorney for Defendant IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA United States of America, Plaintiff, vs. Pedro Rivas-Almeida, Defendant. ) ) ) ) ) ) ) ) ) ) ) CR04-01053-PHX-CKJ(JM) MOTION TO CONTINUE EVIDENTIARY HEARING (First Request)
It is expected that excludable delay under Title 18, United States Code, ยง3161(h)(1)(F) will occur as a result of this motion or an order based thereon. Defendant, Pedro Rivas-Almeida, through undersigned counsel, Rosemarie Valdez, Assistant Federal Public Defender, requests a 1-week continuance of the Evidentiary Hearing presently set for May 16, 2007, at 9:30 a.m. This request is made for the following reasons: 1. 2. Undersigned counsel hereby requests that evidentiary hearing be set with the change of plea hearing on May 23, 2007, at 2:00 p.m. Undersigned counsel will need additional time to review. Assistant U.S. Attorney Angela Martinez has been contacted and she has no objection to the motion to continue. May 15, 2007. JON M. SANDS Federal Public Defender
21 3. 22 23 24 25 26 27 ECF Copy to: Angela Martinez, AUSA 28
RESPECTFULLY SUBMITTED:
/s/Rosemarie Valdez
ROSEMARIE VALDEZ Assistant Federal Public Defender
Case 2:04-cr-01053-CKJ-JJM
Document 27
Filed 05/15/2007
Page 1 of 1