Free Motion to Continue - 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: February 28, 2006 (Second Request)

Comes now undersigned Counsel and respectfully requests that this Court continue the February 28, 2006 trial date. Furthermore, under the suggestion of Assistant United States Attorney Tim Duax, Counsel would like to request that this Court continue the February 28, 2006 trial date for sixty days. Further, Counsel would like to request that the Motion Hearing that is currently set on February 13, 2006 be continued. The reason for this request is that further, unanticipated investigation is needed due to recent facts that have come to the attention of all parties. Undersigned Counsel has contacted all Co-Counsel for the defendants, and everyone except James Cochran and Barbara Hull indicated that they had no objections. Counsel was unable to ascertain Ms. Hull's and Mr. Cochran's thoughts in regards to this motion due to them not returning Counsel's message prior to the filing of this motion. Assistant United States Attorney Tim Duax does not have any objections to this motion either. 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.

Case 2:03-cr-01164-PGR

Document 365

Filed 01/13/2006

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1 2 3 4 5 6 7 8 9 10 11 By: 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

RESPECTFULLY SUBMITTED this 13th day of January, 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 January 13th, 2006. COPY of the forgoing Delivered and E-Mailed this 13th day of January, 2006 to: Honorable Paul G. Rosenblatt 401 West Washington Street Phoenix, Arizona 85003 [email protected] S/ Candace H. Kent Candace H. Kent

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Case 2:03-cr-01164-PGR

Document 365

Filed 01/13/2006

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