Free Motion to Continue - District Court of Arizona - Arizona

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Kevin L. Burns BURNS, NICKERSON & TAYLOR, PLC 111 W. Monroe, Suite 1500 Phoenix, AZ 85003 (602) 254-0004 Bar #009942 Attorney for Defendant

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA United States of America, Plaintiff, vs. Richard Moses, Defendant ) CR04-00993001-PHX-DGC ) ) ) MOTION TO CONTINUE TRIAL ) ) (Sixth Request) ) ) ) )

Defendant, Richard Moses, by and through undersigned counsel, hereby moves the Court to enter an order continuing the currently set date of, September 13, 2005, for thirty days pursuant to Rule 12, Federal Rules of Criminal Procedure; 18 U.S.C. §3161; and the 4th, 5th, 6th, 8th, and 14th Amendments to the United States Constitution. Undersigned counsel requests a continuance based upon pretrial preparation not yet being completed, and also due to the availability of the court. The assistant United States Attorney has been notified of this request, and has indicated no objection. Excludable delay under 18 U.S.C. §3161(h)(8)(A) will occur as a result of this motion or of an order based thereon.

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Case 2:04-cr-00993-DGC

Document 23

Filed 08/30/2005

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RESPECTFULLY SUBMITTED this

day of August, 2005.

______________________________ Kevin L. Burns BURNS, NICKERSON & TAYLOR, PLC Copies of the foregoing mailed/ hand-delivered this _____ day of August, 2005 to: Honorable David G. Campbell United States District Judge Sandra Day O'Connor U.S. Courthouse, Suite 521 401 West Washington Street, SPC 53 Phoenix, AZ 85003 Fred Battista Assistant U.S. Attorney 40 North Central Ave. Suite 1200 Phoenix, AZ. 85004 Julie Roth BURNS, NICKERSON & TAYLOR, P.L.C

Case 2:04-cr-00993-DGC

Document 23

Filed 08/30/2005

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