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

Defendant DANIEL SAMANIEGO-CACHON, by and through undersigned counsel, hereby requests the Court continue the trial and for an extension of time within which to file motions. The discovery process is ongoing. It is expected the discovery may be complete at the beginning of September, 2006. This counsel has conferred with the Assistant U. S. Lisa Settel and she has no objection to this request. 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 trial date in the above matter and extend the time for filing motions. Dated: June 1, 2006. /s/ Michael S. Reeves MICHAEL S. REEVES, Attorney for Defendant SAMANIEGO-CACHON

Case 2:03-cr-01097-ROS

Document 162

Filed 06/01/2006

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CERTIFICATE OF SERVICE I hereby certify that on this date, June 1, 2006, 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 Settel, Assistant U.S. Attorney by: /s/ Michael S. Reeves

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Case 2:03-cr-01097-ROS Document 162 Filed 06/01/2006 Page 2 of 2