Free Motion to Dismiss All Charges - District Court of Arizona - Arizona

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PAUL K. CHARLTON United States Attorney District of Arizona DAVID A. PIMSNER Assistant U.S. Attorney Arizona State Bar No. 007480 Two Renaissance Square 40 North Central Avenue, Suite 1200 Phoenix, Arizona 85004 Telephone: (602) 514-7500 [email protected]

UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA

United States of America, CR-04-1034-PHX-FJM Plaintiff, MOTION TO DISMISS v. Russel Manzanarez, Defendant. The United States of America, by and through undersigned counsel, respectfully requests the Court to dismiss the above-captioned matter as to defendant, Russel Manzanarez, for the reason that the government agreed to dismiss this case as a term and condition of the plea agreement the defendant entered in CR-05-0037-PHX-EHC. On February 8, 2006, the defendant's plea agreement in CR-05-0037-PHX-EHC was accepted by the Court and he was sentenced consistent with the terms of the plea agreement. Additionally, the defendant's relevant conduct in the above-captioned matter was included in the defendant's relevant conduct in CR-05-0037-PHX-EHC. Accordingly, the government moves to dismiss this matter. Defendant's counsel, Michael Black, has been contacted and he has no objection to the United States' Motion to Dismiss. // // // // //

Case 2:04-cr-01034-FJM

Document 27

Filed 02/08/2006

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Excludable delay under 18 U.S.C. 3161(h) will not occur as a result of this motion and order based thereon. Respectfully submitted 8th day of February, 2006. PAUL K. CHARLTON United States Attorney District of Arizona s/David A. Pimsner DAVID A. PIMSNER Assistant U.S. Attorney CERTIFICATE OF SERVICE
I hereby certify that on February 8, 2006, I electronically transmitted the attached 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 registrant: Michael Black, Esq. 335 E. Palm Lane Phoenix, AZ 85004

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UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA United States of America, Plaintiff, v. Russel Manzanarez, Defendant. Based upon the United States of America's Motion to Dismiss and good cause appearing; IT IS ORDERED dismissing the above-captioned matter as to defendant, Russel Manzanarez. IT IS FURTHER ORDERED that excludable delay under 18 U.S.C. § 3161(h) is found to commence on for a total of days. , 20___ CR-04-1034-PHX-FJM ORDER

DATED this _____ day of

Case 2:04-cr-01034-FJM

Document 27

Filed 02/08/2006

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