Free Motion to Continue - District Court of Arizona - Arizona

1 JON M. SANDS Federal Public Defender 2 850 W. Adams Street, Suite 201 Phoenix, Arizona 85007 3 Telephone: (602) 382-2753 4 DONNA LEE ELM, #012127 Asst. Federal Public Defender 5 Attorney for Defendant [email protected] 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA 8 9 10 11 12 13 14 15 vs. Dominic Perino a/k/a, James D. Perino, Defendant. Dominic Perino, through undersigned counsel, respectfully requests that United States of America, Plaintiff, No. CR-04-1071-PHX-FJM MOTION TO CONTINUE TRIAL AND EXTEND TIME TO FILE PRETRIAL MOTIONS (Third Request)

16 this Court extend the time for filing of pretrial motions for a period of at least thirty 17 (30) days from the current date of September 16, 2005. In addition, defendant 18 requests that the Court continue the trial date for a period of at least thirty (30) days 19 from the current date of October 4, 2005. The reason for the continuances is 20 undersigned counsel is awaiting medical reports and needs additional time for 21 investigation and trial preparation. 22 Defense counsel has contacted Assistant United States Attorney, 23 Clarence Butler, concerning this motion and he has no objection to the requested 24 continuances. 25 . . . 26 . . . 27 . . . 28 . . .

Case 2:04-cr-01071-REJ

Document 29

Filed 09/16/2005

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1 2 4 thereon. 5 6 7 8 9 10 Copy of the foregoing transmitted by CM/ECF 11 this 16th day of September , 2005, to: 12 CLARENCE BUTLER Assistant United States Attorney 13 5400 Federal Plaza, Ste 1500 Hammond, IN 46320 14 Copy mailed to: 15 DOMINIC PERINO 16 Defendant 17 19 20 21 22 23 24 25 26 27 28
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It is expected that excludable delay under Title 18 U.S.C. Section

3 3161(h)(8)(A) and (h)(1)(F) may result from this motion or from an order based Respectfully submitted: September 16, 2005. JON M. SANDS Federal Public Defender s/Donna Lee Elm DONNA LEE ELM Asst. Federal Public Defender

s/Donna E. Elm 18 DONNA E. ELM

Case 2:04-cr-01071-REJ

Document 29

Filed 09/16/2005

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