Free Motion to Continue - District Court of Arizona - Arizona

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Joy Bertrand PO Box 60334 Phoenix, AZ 85082 AZ State Bar No. 024181 Office ­ 480-656-3919 Cell ­ 414-687-4932 Fax ­ 480-361-4694 Email ­ [email protected] www.joybertrandlaw.com Attorney for the Defendant

IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA ) ) ) v. ) ) CARL DUANE WATSON, ) Defendant. ) _______________________________________) UNITED STATES, Plaintiff, No. 2:04-CR-00113-MHM-1 DEFENDANT'S SECOND MOTION TO CONTINUE ADMIT/DENY HEARING

NOW COMES the Defendant, Carl Duane Watson, by his attorney, Joy Bertrand, to ask this Court to continue his January 8, 2008 his supervised release violation to be consolidated scheduling-wise, with the Defendant's new case, United States v. Carl Duane Watson, 2:07-CR-01241-MHM. As further grounds therefore, the Defendant submits the following: Counsel has been appointed to represent Mr. Watson in this matter, which is set for an admit/deny hearing on December 17, 2007. The Defendant has also been charged in United States v. Carl Duane Watson, 2:07CR-01241-MHM. The basis for the revocation of the Defendant's supervised release is the alleged bank robbery in the new case. That case is set for trial January 8, 2008 before

Case 2:04-cr-00113-MHM

Document 121

Filed 01/04/2008

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this Court. On January 2, 2008, the Defendant's codefendant in this new case filed a motion to continue the trial and to extend time to file pretrial motions. The Defendant did not object to that motion Given the overlap in the allegations between these two cases, the admit/deny hearing in this case will be most efficiently resolved with the new case. Assistant United States Attorney Allison Bacchus has informed defense counsel that the Government has no objection to this request. The Court will find attached to this motion a proposed order. Respectfully submitted this Fourth day of January, 2008. s/Joy Bertrand Joy Bertrand Attorney for Defendant

Case 2:04-cr-00113-MHM

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 s/Joy Bertrand Joy Bertrand Attorney for Defendant Respectfully submitted this Fourth day of January, 2008. CERTIFICATE OF SERVICE On January 4, 2008, I, Joy Bertrand, attorney for the Defendant, Carl Duane Watson, filed the Defendant's Second Motion to Continue Admit/Deny Hearing and proposed order with the Arizona District Court's electronic filing system. Based on my training and experience with electronic filing in the federal courts, it is my understanding that a copy of this request will be electronically served upon opposing counsel, Allison Bacchus, upon its submission to the Court.

Case 2:04-cr-00113-MHM

Document 121

Filed 01/04/2008

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