Free Motion to Continue - District Court of Arizona - Arizona

LOYD C. TATE

2600 N. CENTRAL AVE., STE. 900 PHOENIX, ARIZONA 85004 (602) 263-5199 State Bar No. 014276 Attorney for Defendant

ATTORNEY AT LAW

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA

) ) Plaintiff, ) NO. CR-04-929-PHX-NVW ) v. ) MOTION TO CONTINUE ) ) RUDY S. ROCHA, ) ) Defendant ) ____________________________________)

UNITED STATES OF AMERICA,

Defendant Rudy Rocha by and through undersigned counsel requests the Court to continue the trial date currently set for November 1, 2005 for a period of 60 days. The government has also by Motion requested the court designate the case complex pursuant to 18 U.S.C. § 3161(h)(8)(B)(ii). Counsel is in the continuing process of completing review of the approximate 20,000 pages of discovery in this matter. Counsel has conferred with the Assistant U.S. Attorney Gregory Fouratt and he has no objection to this motion. Excludable delay under Title 18 U.S.C. § 3161(h)(1)(F) and (8)(A) will occur as a result of this motion or from an order based thereon. The Defendant will waive all applicable time

Case 2:04-cr-00929-NVW

Document 24

Filed 10/14/2005

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pursuant to Title 18 U.S.C. § 3161. Respectfully submitted this 14th day of October, 2005. By s/Loyd C. Tate Loyd C. Tate Attorney for Defendant I hereby certify on October 14, 2005, I electronically transmitted the attached document to the Clerk's Office using the CM/ECF System for filing and transmittal of a Notice of Electronic Filing to the following CM/ECF registrants: The Honorable Neil V. Wake United States District Court Gregory J. Fouratt Assistant U.S. Attorney By s/Loyd C. Tate

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Case 2:04-cr-00929-NVW

Document 24

Filed 10/14/2005

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