Free Motion to Continue - District Court of Arizona - Arizona

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Robert Bruce Stirlin g, II, Esq. Attorney at Law 33 West Willetta Street Phoenix, Arizona 85003 Tel. (602) 460-5631 Fax (602) 285-1224 State Bar No. 006037 [email protected] Attorney for Defendant IN THE UNITED STATES DISTRICT COURT

7 FOR THE DISTRICT OF ARIZONA 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 .... v. MIGUEL RAMIREZ UREA, AKA MIGUEL F. OROPEZA, Defendant. UNITED STATES OF AMERICA, Plaintiff, ) ) ) ) ) ) ) ) ) )

CA SE NO . CR 04-00868-001-PHX-FJM MOTION TO CO NTINUE JURY TRIAL [THIRD]

The defendant, Miguel Ramirez Urea, through counsel undersigned, hereby moves this Court for its order continuing the jury trial now set for September 7, 2005, at 9:00, pursuant to Rule 12, Federal Rules of Criminal Procedure; 18U.S.C. §3161; and the 4 th, 5 th, 6 th, 8 th, and 14th Amendments to the United States Constitution. Although counsel have discussed this case, no plea agreement offer has yet been tendered. Defense counsel anticipates Mr. Ramirez-Urea will accept an agreement after counsel receives an offer and reviews it with him. In addition to investigating and resolving Mr. Ramirez-Urea 's charge in this case, additional time is needed for defense counsel to again review all of the discovery with the defendant, complete the investigation, and to prepare for trial. Defense counsel contact Assistant United States Attorney, W illiam Solomon, who informed defense counsel he did not oppose defendant's motions. Excludable delay under 18 U.S.C. §3161(h)(8)(A) and (B)(i) may result from this motion

Case 2:04-cr-00868-FJM

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Filed 09/02/2005

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or from an order based thereon. Respectfully submitted this 2nd day of September, 2005.

/s/ Robert Bruce Stirling, II ________________________________ Robert Bruce Stirling, II, Esq. Attorney for Defendant

Copy of the foregoing transmitted by CF/ECM for filing this 2nd day of September, 2005, to: William Solomon Assistant United States Attorney US A ttorney's Office 40 N Central Ave Suite 1200 Phoenix, AZ 85004-4408 Email: [email protected] Attorney for the Government Copy of the foregoing document mailed this 2nd day of September, 2005, to: Manuel Ramirez-Urea /s/ Robert Bruce Stirling, II By _____________________________

Case 2:04-cr-00868-FJM

Document 13

Filed 09/02/2005

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