Free Motion to Continue - 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

UNOPPOSED MOTION TO CONTINUE TRIAL AND EXTEND TIME TO FILE PRETRIAL MOTIONS

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. Counsel 22 also requests additional time to file pretrial motions. 23 24 25 stated there is no objection to this request. This continuance is requested for the following Counsel has contacted Assistant United States Attorney, David Pimsner, who has

26 reason: 27 28 1

Case 2:04-cr-01029-MHM

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1. 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) ). 2. Trial is scheduled for November 29, 2005. Defense counsel has recently been

5 retained in this matter and has had insufficient time to prepare pretrial motions and 6 7 8 3. Defendant's file is over 5 inches thick and counsel needs reasonable time to prepare for trial.

9 effectively prepare for trial with an exercise of due diligence (Title 18, USC §3161 (h) (8) 10 11 12 13 14 15 16 17 18 Copy electronically sent to: This motion is not made for the sole purpose of delay, but in the interest of justice. RESPECTFULLY SUBMITTED this 26 th day of October, 2005. LAW OFFICE OF ERIN M. ALAVEZ, LLC (B) (iv) ).

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

19 U.S. District Court 20 David A. Pimsner 21 US Attorney's Office 22 23 24 25 26 27 28 2 ______________________

Case 2:04-cr-01029-MHM

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Filed 10/27/2005

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