Free Motion to Continue Trial - District Court of Arizona - Arizona

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Kent & Ryan, P.L.C.
45 West Jefferson, Suite 206 LUHRS Tower Phoenix, Arizona 85003 (602) 277-8888 (Office) (602) 253-3105 (Fax) [email protected] (E-mail) Candace Hewitt Kent, #013285

Attorney for the Defendant
UNITED STATES DISTRICT COURT 7 DISTRICT OF ARIZONA 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 ) ) Plaintiff, ) ) vs. ) ) Paolo Alicia Ruiz, ) ) Defendant. ) ____________________________________ ) United States of America, Case No. CR 2003-01164-011-PHX-PGR MOTION TO CONTINUE TRIAL AND MOTION TO CONTINUE MOTION HEARING Trial Date: June 20, 2006

Comes now undersigned Counsel and respectfully requests that this Court continue the June 20, 2006 trial date. Furthermore, under the suggestion of Assistant United States Attorney Timothy Duax, Counsel would like to request that this Court continue the June 20, 2006 trial date until September, 2006. Further, Counsel would like to request that the Motion Hearing that is currently set on June 12, 2006 be continued. The reason for this request is that further investigation is needed regarding final factual details of this matter before any resolution of this case can be achieved. Undersigned Counsel has contacted counsel for remaining codefendants Evans, Allen, and Campbell, and none have an objection. Assistant United States Attorney Timothy Duax does not have an objection to this motion. Indeed, the United States joins in the Motion to Continue for the reason that codefendant Paul Allen, for reasons known to this Court, is unavailable for the Motion Hearing and the Trial date. The United States believes the interests of justice and judicial economy would be best served by the granting of this motion.

Case 2:03-cr-01164-PGR

Document 430

Filed 06/07/2006

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Excludable delay under 18 U.S.C. § 3161(h)(1)(F) may occur as a result of this motion or of an order based thereon.

RESPECTFULLY SUBMITTED this 7th day of June, 2006.

Kent & Ryan, P.L.C
By:

S/ Candace H. Kent Candace H. Kent 45 West Jefferson, Suite 206 Phoenix, Arizona 85003 Attorneys for the Accused

ELECTRONICALLY FILED on June 7th, 2006. COPY of the forgoing E-Mailed this 7th day of June, 2006 to: Honorable Paul G. Rosenblatt [email protected] S/ Candace H. Kent Candace H. Kent

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Case 2:03-cr-01164-PGR

Document 430

Filed 06/07/2006

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