Free Motion to Continue Trial - District Court of Arizona - Arizona

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MICHAEL V. BLACK Attorney at Law 335 East Palm Lane Phoenix, Arizona 85004 Telephone: (602) 265-7200 Facsimile: (602) 265-2431 E-Mail: [email protected] State Bar Number 007671 Attorney for Russel Manzanarez

UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA
) ) Plaintiff, ) ) ) ) vs. ) ) ) RUSSEL MANZANAREZ, ) ) Defendant. ) __________________________________ ___) UNITED STATES OF AMERICA, CR04-1034-PHX-FJM

MOTION TO CONTINUE TRIAL

(Seventh Request) (No Oral Argument Requested)

Michael V. Black, attorney for defendant, Russel Manzanarez, respectfully requests a trial continuance of two (2) weeks or to a date convenient with this Court's calendar. This Motion is based on the attached Memorandum and files and records in the case. It is expected that excludable delay under Title 18 U.S.C. Section 3161(h)(1)(f) may occur as a result of this Motion or from an Order based thereon. RESPECTFULLY SUBMITTED this 1st day of February, 2006. /s/ Michael V. Black _____________________________ MICHAEL V. BLACK

Case 2:04-cr-01034-FJM

Document 25

Filed 02/01/2006

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Case 2:04-cr-01034-FJM

MEMORANDUM To adequately prepare for trial, undersigned counsel requests a continuance of the current trial date of February 7, 2006, for a period of two (2) weeks or to date convenient with this Court's calendar. The reasons for the requested continuance are as follows. Russel Manzanarez has entered a plea in a related case, CR2005-1234-EHC-PHX, and was scheduled to be sentenced on January 30, 2006. However, at the sentencing hearing at the request of the Court, the sentencing has been continued until Feb. 8, 2006. As such it is anticipated that Mr. Manzanares will be sentenced within the next ten (10) days. Therefore, it is requested that this Count continue the trial in the above entitled matter for a period of two (2) weeks. Further, pursuant to Local Rule 1.10 (j), undersigned counsel certifies that he has personally contacted the prosecutor in the instant matter, Assistant U.S. Attorney David A. Pimsner, and Mr. Pimsner indicated that he had no objection to the proposed continuance. RESPECTFULLY SUBMITTED this 1st day of February, 2006.

I hereby certify that on Feb. 1, 2006, I electronically transmitted the attached document to U.S. District Clerk of Court using the CM/ECF system for Filing and transmittal of a Notice of Electronic Filing to the following CM/ECF registrants: [email protected]

/s/ Michael V. Black ____________________________ MICHAEL V. BLACK

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Document 25

Filed 02/01/2006

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