Free Motion to Continue - District Court of Arizona - Arizona

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 27 28

MICHAEL TERRIBILE 111 West Monroe, Suite 1650 Phoenix, Arizona 85003 (602) 254-5544 (602)254-9263 fax State Bar No. 006725 Attorney for Defendant Hudson

IN THE UNITED STATES DISTRICT COURT IN AND FOR THE DISTRICT OF ARIZONA

Defendant Hudson, through undersigned counsel respectfully moves this Court to continue his trial now scheduled for October 11, 2005 T h e

Government is willing to present a plea offer, contingent upon establishment of the Defendant's medical condition. Undersigned counsel has requested the Defendant's recent medical records from CCA, and did not receive them as promised prior to the Settlement Conference today. Therefore, the Defendant requests a continuance of the trial for an additional thirty days to obtain the necessary medical information and records. Excludable delay under 18 U.S.C. § 3161(h)(1)(F) may occur as a result of this motion or any order based thereon. /// ///

Case 2:04-cr-01065-DGC

Document 54

HT

) ) Plaintiff, ) ) v ) ) ) Danny Lynn Hudson, ) ) Defendant. ) _______________________________ )

United States of America,

Case No. CR04-1065-PHX-DGC

MOTION TO CONTINUE TRIAL (5 Request)

Filed 09/26/2005

Page 1 of 2

1 2 3 4 5 6 7 8 9

RESPECTFULLY SUBMITTED this 26th day of September, 2005.

s/Michael Terribile MICHAEL TERRIBILE Attorney for Defendant Hudson

Filed this 26th day of September via ECF, and a

COPY of the foregoing hand-delivered this 26th day of September, 2005 10 to:
11 The Honorable David G. Campbell 12 401 West Jefferson 13 14 By: s/M. Shepard 15 16 17 18 19 20 21 22 23 24 25 26 27 28

U.S. DISTRICT COURT JUDGE Phoenix, Arizona 85003

-2-

Case 2:04-cr-01065-DGC

Document 54

Filed 09/26/2005

Page 2 of 2