Free Motion to Continue - District Court of Arizona - Arizona

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MICHAEL S. REEVES, ESQ. State Bar Number: 010420 1212 East Osborn Phoenix, Arizona 85014 Tel: [602] 604-7577 Fax: [602] 604-7555 Attorney for Defendant UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA UNITED STATES OF AMERICA, Plaintiff, Vs. DANIEL SAMANIEGO-CACHON, Defendant. ) ) ) ) ) ) ) ) ) ) ) NO. CR03-01097-003-PHX-ROS MOTION TO CONTINUE STATUS CONFERENCE

Defendant DANIEL SAMANIEGO-CACHON, by and through undersigned counsel, hereby requests the Court continue the status conference currently set for July 2, 2007, for a period of approximately 30 days, and for an extension of time within which to file motions. Assistant U.S. Attorney Lisa Jennis Settel, has no objection to this request. The evaluation of the Defendant is not yet complete, and the subsequent final report is supposed to be available any day now. Further, counsel for Defendant will be on vacation with his family during the week of July 1, 2007, and it would create a hardship to cancel reservations at this time. This motion is made in good faith and not for purposes of delay. The interests of justice served by a continuance outweigh the interests of the Defendant and the public in a speedy trial. Excludable delay under 18 U.S.C. §3161(h) will occur as a result of this motion or from an order based thereon. WHEREFORE, it is requested that the Court continue the status conference for a period of approximately 30 days, and extend the time for filing motions.

Case 2:03-cr-01097-ROS

Document 194

Filed 06/20/2007

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Dated: June 20, 2007. /s/ Michael S. Reeves MICHAEL S. REEVES, Attorney for Defendant SAMANIEGO-CACHON CERTIFICATE OF SERVICE I hereby certify that on this date, June 20, 2007, I electronically transmitted the attached document to the Clerk's Office using the CM/ECF System for filing and transmittal of Notice of Electronic Filing to the following CM/ECT registrants: Lisa Jennis Settel, Assistant U.S. Attorney by: /s/ Michael S. Reeves

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Case 2:03-cr-01097-ROS Document 194 Filed 06/20/2007 Page 2 of 2