Free Motion to Continue - District Court of Arizona - Arizona

FLORENCE & BELL, LTD. Sherry Bell 45 West Jefferson Tenth Floor, Luhrs Tower Phoenix, Arizona 85003 (602) 258-8451 Bar I.D. #006819 Attorney for Defendant

IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA UNITED STATES OF AMERICA, Plaintiff, v. JAOD DODDS, Defendant. ) ) ) ) ) ) ) ) ) ) No. CR2004-00951-PHX-DGC MOTION TO CONTINUE COMPETENCY HEARING

Hrg: October 23, 2006 (Assigned to the Hon. Campbell)

The defendant, acting through counsel, hereby requests this Court to continue the Competency hearing which is currently scheduled for October 23, 2006, at 1:30 p.m. This motion is made in good faith and not for the purpose of delay. Extraordinary circumstances exist and the continuance is indispensable to the interests of justice as Counsel is in trial in the matter of State v. Nicholas Rohn, in Kingman, Arizona, before the Honorable Richard Weiss from October 16 through October 26. Counsel requests a brief continuance and asks that this matter be reset in not less than two weeks. Counsel has spoken to Assistant United States Attorney, Bill Solomon, and he has no objection to this continuance. Excludable delay under 18 U.S.C.(h)(1)(f) may occur as a result of this motion or an order based thereon.

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Case 2:04-cr-00951-DGC

Document 53

Filed 10/17/2006

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RESPECTFULLY SUBMITTED this 17th

day of October, 2006.

FLORENCE & BELL, LTD.

/s/: Sherry Bell Sherry Bell 45 West Jefferson Tenth Floor, Luhrs Tower Phoenix, Arizona 85003

CERTIFICATE OF SERVICE I hereby certify that on the 17th day of October , 2006, I electronically filed the

foregoing with the Clerk of the Court using the CM/ECF filing system, which will send notification of such filing to counsel for all parties. /s/: Heather L. Babel Heather L. Babel

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Case 2:04-cr-00951-DGC

Document 53

Filed 10/17/2006

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