Free Motion to Continue Trial - 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 TRIAL AND EXTEND TIME TO FILE MOTIONS (Eighth)

Defendant DANIEL SAMANIEGO-CACHON, by and through undersigned counsel, hereby requests the Court continue the trial currently set for June 5, 2007, for a period of approximately 60 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 will take approximately two weeks. Further, this counsel is scheduled for trial on June 5, 2007 in the following matters: United States v. Valdez-Garcia, No. CR07-00392-001-PHX-SMM; United States v. Osuna-Sota, No. CR07-371-PHX-NVW; United States v. Avilez-Acosta, No. CR07-231-002 PHX-NVW; State of Arizona v. Dahlgren et al., No. CR2006-009614-001-DT; and a domestic relations trial, McClure and McClure, Maricopa County Superior Court No. FN2006-001680. 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.

Case 2:03-cr-01097-ROS

Document 187

Filed 04/26/2007

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WHEREFORE, it is requested that the Court continue the trial date for a period of approximately 60 days, and extend the time for filing motions. Dated: April 26, 2007. /s/ Michael S. Reeves MICHAEL S. REEVES, Attorney for Defendant SAMANIEGO-CACHON CERTIFICATE OF SERVICE I hereby certify that on this date, April 26, 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 187 Filed 04/26/2007 Page 2 of 2