Free Motion to Continue - District Court of Arizona - Arizona

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Neal C. Taylor BURNS, NICKERSON & TAYLOR, PLC 111 W. Monroe, Suite 1500 Phoenix, AZ 85003 (602) 254-0004 Bar #7515 Attorney for Defendant

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA United States of America, ) CR 04-0982-PHX-SRB ) ) ) ) MOTION TO CONTINUE TRIAL ) ) (Sixth Request) ) ) )

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Plaintiff,
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vs.
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Pedro Meza-Ochoa et al., Defendant

Defendant, Pedro Meza-Ochoa, by and through undersigned counsel, hereby moves the Court to continue the trial currently set for, September 6, 2005, for sixty 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. On August 22, 2005 counsel for the Defendant filed a Motion to Withdraw due to an ethical conflict. That matter is still pending before the court. If new counsel is appointed, that counsel will need additional time to prepare the case. The Assistant United States Attorney has no objection to this continuance. All

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other co-defendant cases have been resolved.
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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.

RESPECTFULLY SUBMITTED this

day of August 2005.

s/Neal C. Taylor Neal C. Taylor BURNS, NICKERSON & TAYLOR, PLC

Copies of the foregoing e-mailed/ hand-delivered this _____ day of August 2005, to: The Honorable Susan R. Bolton 401 West Washington Phoenix, AZ 85003

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Case 2:04-cr-00982-SRB

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