Free Motion to Continue - District Court of Arizona - Arizona

Rena P. Glitsos
45 W. Jefferson, Suite 512 Phoenix, AZ 85003 (602) 528-0882 AZ State Bar No. 013009 Attorney for Defendant

IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA

________________________________________ ) ) UNITED STATES OF AMERICA ) ) Plaintiff, ) ) v. ) ) ) FERNANDO WHITE, ) ) Defendant. ) ) _______________________________________ )

No. 94/CR00657-001-PHX-NVW MOTION TO CONTINUE AND EXTEND TIME FOR FILING MOTIONS (Second Requested Continuance by Undersigned Counsel)

Defendant, through counsel, respectfully moves the Court to continue trial in the abovereferenced matter for 60 days as the defense needs additional time to complete discovery and investigation. Defense counsel was appointed in August after defendant had pled and prior to sentencing. At sentencing, defendant withdrew from the plea and the case was set for trial. This is the second request for a continuance made by undersigned counsel. 1. Defense counsel has contacted attorney for the Government, Sharon Sexton, who has no

objection to the court granting an extension of time herein. 2. The ends of justice served by the granting of this Motion to Continue outweigh the best

Case 2:04-cr-00657-NVW

Document 45

Filed 10/18/2005

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interests of the public and the Defendant in a speedy trial. Excludable delay under 18 U.S.C. Section 3161(h) may occur as a result of this Motion or from any attendant orders. 3. Therefore, it is respectfully requested that the Court grant the defendants Motion to

Continue. 4. In light of the request for a continuance defendant respectfully moves the Court to extend

the deadline for filing pre-trial motions accordingly. Defendant further moves the Court to vacate the status hearing set in this matter. Respectfully submitted this 18h day of October, 2005 at Phoenix, Arizona.

By/s/ Rena P. Glitsos

Copy of the foregoing was mailed/faxed/delivered this 18th day of October, 2005 to: The Honorable Neil V. Wake United States District Court Judge 401 W. Washington Phoenix, AZ 85003 Assistant United States Attorney Sharon Sexton Two Renaissance Square 40 N. Central Phoenix, AZ 85004

By /s/ Rena P. Glitsos

Case 2:04-cr-00657-NVW

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Filed 10/18/2005

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Case 2:04-cr-00657-NVW

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Filed 10/18/2005

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