Free Motion to Continue - District Court of Arizona - Arizona

1 JON M. SANDS Federal Public Defender 2 District of Arizona 850 W. Adams, Suite 201 3 Phoenix, Arizona 85007 Telephone: (602) 382-2721 4 Facsimile: (602) 382-2800 5 JEANETTE E. ALVARADO, #016111 Asst. Federal Public Defender 6 Attorney for Defendant [email protected] 7 IN THE UNITED STATES DISTRICT COURT 8 FOR THE DISTRICT OF ARIZONA 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 vs. David Hernandez-Salas, Defendant. David Hernandez-Salas, through undersigned counsel, moves to continue the admit/deny hearing presently scheduled for December 3, 2007 for a period of at least thirty (30) days. The continuance is requested to allow the Defendant to resolve both the instant supervised release matter, with the new illegal re-entry charge that undersigned counsel has been advised by the government is forthcoming. Normally, the government offers a plea agreement that will allow Defendant to resolve both matters. Therefore, to allow Defendant the opportunity to receive and consider such a plea offer, a continuance of thirty (30) days on the Admit/Deny Hearing is requested. Assistant U.S. Attorney, Michael Lee, has no objection to the requested continuance. United States of America, Plaintiff, No. CR-04-161-PHX-JAT MOTION TO CONTINUE ADMIT/DENY HEARING (First Request)

Case 2:04-cr-00161-JAT

Document 31

Filed 11/29/2007

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It is expected that excludable delay under Title 18 U.S.C. § Respectfully submitted: November 29, 2007. JON M. SANDS Federal Public Defender s/ Jeanette E. Alvarado JEANETTE E. ALVARADO Asst. Federal Public Defender

2 3161(h)(1)(F) may occur as a result of this motion or from an order based thereon.

9 Copy of the foregoing transmitted by ECF this 27th day of November, 2007, 10 to: 11 CLERK'S OFFICE United States District Court 12 Sandra Day O'Connor Courthouse 401 W. Washington 13 Phoenix, Arizona 85003 14 MICHAEL LEE Assistant U.S. Attorney 15 United States Attorney's Office Two Renaissance Square 16 40 N. Central Avenue, Suite 1200 Phoenix, Arizona 85004-4408 17 Copy mailed to: 18 MELISSA SULLIVAN 19 United States Probation Sandra Day O'Connor Courthouse 20 401 W. Washington, Suite 160 Phoenix, Arizona 85003 21 DAVID HERNANDEZ-SALAS 22 Defendant 23 24 25 26 27 28 s/J. Alvarado
\ContAdmitDenyMTN

Case 2:04-cr-00161-JAT

Document 31

Filed 11/29/2007

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