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.

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NO. CR03-01097-003-PHX-ROS MOTION TO CONTINUE HEARING

Defendant DANIEL SAMANIEGO-CACHON, by and through undersigned counsel, hereby requests the Court continue the hearing currently set for September 17, 2007, for a period of approximately 30 days and for an extension of time within which to file motions. Assistant U.S. Attorney Lisa Jennis Settel, has no objection to this request. Counsel for the Defendant has not had an opportunity to meet with the Defendant personally for a long period of time and needs an opportunity to communicate with the Defendant. 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 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 for a period of

Case 2:03-cr-01097-ROS

Document 201

Filed 09/11/2007

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approximately 30 days, extend the time for filing motions, and vacate the status conference. Dated: September 11, 2007. /s/ Michael S. Reeves MICHAEL S. REEVES, Attorney for Defendant SAMANIEGO-CACHON CERTIFICATE OF SERVICE I hereby certify that on this date, September 11, 2007, 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 201

Filed 09/11/2007

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