Free Motion to Continue - District Court of Arizona - Arizona

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MICHAEL S. REEVES, ESQ. State Bar Number: 010420 1212 East Osborn Phoenix, Arizona 85014 Tel: [602] 604-7577 Fax: [602] 604-7555 Attorney for Defendant UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA UNITED STATES OF AMERICA, Plaintiff, Vs. DANIEL SAMANIEGO-CACHON, Defendant. ) ) ) ) ) ) ) ) ) ) ) NO. CR03-01097-003-PHX-ROS MOTION TO CONTINUE TRIAL AND HEARING (13th)

Defendant DANIEL SAMANIEGO-CACHON, by and through undersigned counsel, hereby requests the Court continue the hearing currently set for February 11, 2008, to a date the first part of April; continue the trial set for April 1, 2008; and extend the time within which to file motions. This motion is based upon the previously submitted report to the Court regarding the meeting between Dr. Hamadi and client and the agreement to begin to take the prescribed medications. The drugs will take 6 to 8 weeks to take effect. The Defendant will then need to be re-evaluated by Dr. Walter and the doctor will need time to prepare a report. Assistant U.S. Attorney Lisa Jennis Settel has no objection to this request. This motion is made in good faith and not for purposes of delay. The interests of justice served by a continuance outweigh the interests of the Defendant and the public in a speedy hearing and trial. Excludable delay under 18 U.S.C. §3161(h) will occur as a result of this motion or from an order based thereon. WHEREFORE, it is requested that the Court continue the hearing to a date the first part of April, and thereafter the trial for a period of approximately 30 days and extend the time for

Case 2:03-cr-01097-ROS

Document 226

Filed 01/18/2008

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filing motions. Dated: January 18, 2008. /s/ Michael S. Reeves MICHAEL S. REEVES, Attorney for Defendant CERTIFICATE OF SERVICE I hereby certify that on this date, January 18, 2008, I electronically transmitted the attached document to the Clerk's Office using the CM/ECF System for filing and transmittal of Notice of Electronic Filing to the following CM/ECT registrants: Lisa Jennis Settel, Assistant U.S. Attorney by: /s/ Michael S. Reeves

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Case 2:03-cr-01097-ROS

Document 226

Filed 01/18/2008

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