Free Motion to Continue - District Court of Arizona - Arizona

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FEOLA & TRAICA
A PROFESSIONAL CORPORATION ATTORNEYS and COUNSELLORS at LAW

2800 N. Central Avenue, Suite 1400 Phoenix, Arizona 85004-1045 [email protected] _____________

(602) 277-7473 Fax (602) 274-2129

David L. Lockhart State Bar No. 018475 Attorneys for Defendant IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA UNITED STATES OF AMERICA, Plaintiff, vs. MICHAEL CRAIG ANDERSON, Defendant. No. CR 04-01281-001-PHX-DGC MOTION TO CONTINUE/RESET STATUS CONFERENCE

DEFENDANT MICHAEL CRAIG ANDERSON, by and through undersigned counsel, respectfully moves this Honorable Court for an Order continuing or in the alternative resetting the Status Conference in this matter presently scheduled for February 24, 2006 at 4:00 p.m. subject to the Court's calendar for the foregoing reason. Undersigned counsel will be out of town in Indianapolis, Indiana on a prior engagement. Undersigned has already purchased a plane ticket and made hotel reservations for the upcoming trip. If the Court's calendar can accommodate, undersigned would be available for a Status Conference on February 17, 2006 at the 4:00 p.m. Further, undersigned could be available by telephone on February 24, 2006 at 4:00 p.m. should the Court's calendar be unable to accommodate the request discussed herein.

Case 2:04-cr-01281-DGC

Document 83

Filed 02/07/2006

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Undersigned avows that he has attempted contacted Assistant United States Attorney, John Z. Boyle, regarding his position to the subject Motion. Undersigned avows that as of the date of this Motion, undersigned has been unable to confirm whether Mr. Boyle has any objection to the Court granting the relief requested herein. Further, undersigned avows that he has attempted to contact Patricia Gitre, counsel for coDefendant, Gina Anderson, regarding her position to this Motion. As of the date of this Motion, undersigned has been unable to confirm Ms. Gitre's position regarding this matter. For the reasons stated herein, Defendant Michael Craig Anderson, by and through undersigned counsel, respectfully moves this Court for an Order continuing, or in the alternative resetting the Status Conference presently scheduled for February 24, 2006 at 4:00 p.m., subject to the Court's calendar. It is expected that excludable delay under 18 U.S.C. §3161(h)(8)(A); (B)(iv) and (h)(1)(f) will not result from this motion or from an order based thereon.. RESPECTFULLY SUBMITTED this 7th day of February, 2006. FEOLA & TRAICA, P.C.

FEOLA & TRAICA, P.C.

10
2800 N. Central Ave., Suite 1400 Phoenix, Arizona 85004-1045

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By

s/ David L. Lockhart David L. Lockhart, Esq. 2800 N. Central Avenue Suite 1400 Phoenix, AZ 85004 Attorneys for Defendant

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CERTIFICATE OF SERVICE I certify that on February 7 , 2006, I electronically transmitted this document to the Clerk's Office using the CM/ECF system for filing and transmittal of a Notice of Electronic Filing to the following CM/ECF registrants: John Z. Boyle, Esq. Assistant U.S. Attorney Two Renaissance Square 40 North Central Avenue Suite 1200 Phoenix, Arizona 85004-4408 Patricia Gitre, Esq. 331 N. First Avenue, Suite 150 Phoenix, Arizona 85003 Attorney for co-Defendant Gina Anderson

FEOLA & TRAICA, P.C.

10
2800 N. Central Ave., Suite 1400 Phoenix, Arizona 85004-1045

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