Free Motion to Continue - District Court of Arizona - Arizona

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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 September 13, 2005. Counsel has been unable to contact the Defendant for months. Mr. Hudson also failed to remain in contact with his Pretrial Services officer, and was picked up on a warrant this past Friday, August 26, 2005. At that time he appeared in court in bare feet and was, to some extent, incoherent. The Government is willing to present a plea offer, contingent upon establishment of the Defendant's medical condition. Undersigned counsel will need at least thirty (30) days to get those medical records. Therefore, the Defendant requests a continuance of the trial for an additional thirty days. Excludable delay under 18 U.S.C. § 3161(h)(1)(F) may occur as a result

Case 2:04-cr-01065-DGC

Document 42

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

United States of America,

Case No. CR04-1065-PHX-DGC

MOTION TO CONTINUE TRIAL (4 Request)

Filed 08/29/2005

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of this motion or any order based thereon.

RESPECTFULLY SUBMITTED this 29th day of August, 2005.

s/Michael Terribile MICHAEL TERRIBILE Attorney for Defendant Hudson

Filed this 29th day of August via ECF, and a COPY of the foregoing 29th day of August, 2005

11 hand-delivered this 12 to:

13 The Honorable David G. Campbell 14 401 West Jefferson 15 16 By: s/M. Shepard 17 18 19 20 21 22 23 24 25 26 27 28

U.S. DISTRICT COURT JUDGE Phoenix, Arizona 85003

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Case 2:04-cr-01065-DGC

Document 42

Filed 08/29/2005

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