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

1 ERIN M. ALAVEZ ATTORNEY AT LAW 2 2813 E. 22nd St. Tucson, Arizona 85713 3 Tel: (520) 722-0778 Fax: (520) 733-3774 4 AZ-SBN: 021108 5 Attorney for Defendant 6 7 8 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA ) ) ) Plaintiff ) ) ) vs. ) ) ) JOSE RAMON MACHADO-SANCHEZ ) ) ) Defendant ) ___________________________________ ) CASE NO. 04-CR-01029-PHX-MHM

9 UNITED STATES OF AMERICA 10 11 12 13 14 15 16 17

MOTION TO CONTINUE TRIAL (3rd Request) HON. MARY H. MURGUIA

It is expected that excludable delay under Title 18, United States Code, Section

18 §3161(h)(1)(F) will occur as a result of this motion or an order based thereon. 19 Defendant, Jose Ramon Machado-Sanchez, through the undersigned counsel, 20 21 Erin m. Alavez, respectfully requests a ninety (90) day continuance of trial date. 22 23 24 25 26 27 28 1 reason: 1. Counsel for Defendant has become aware of Defendant's potential mental Counsel has contacted Assistant United States Attorney, David Pimsner, who has stated there is no objection to this request. This continuance is requested for the following

Case 2:04-cr-01029-MHM

Document 56

Filed 02/01/2006

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1 impairment. Counsel for Defendant will be filing a separate request for medical 2 3 4 of his medical examination is known. 5 6 7 8 9 10 LAW OFFICE OF ERIN M. ALAVEZ, LLC 11 12 13 14 Copy electronically sent to: 15 U.S. District Court 16 David A. Pimsner 17 US Attorney's Office 18 Erin M. Alavez, Esq. 19 20 21 22 23 24 25 26 27 28 2 This motion is not made for the sole purpose of delay, but in the interest of justice. RESPECTFULLY SUBMITTED this 01 st day of February, 2006. 2. The ends of Justice served by a continuance outweigh the best interests of the public or defendant in speedy trial, (Title 18, USC §3161 (h) (8) (A) ). evaluation. It is in the best interest for Defendant no to proceed to trial until the outcome

s/Erin M. Alavez,
Erin M. Alavez, Esq. Attorney at Law

Case 2:04-cr-01029-MHM

Document 56

Filed 02/01/2006

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