Free Motion to Continue - District Court of Arizona - Arizona

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

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 NOTICE OF CONFLICT AND MOTION TO CONTINUE STATUS HEARING RE: PSYCHOLOGICAL EVALUATION

COMES NOW Michael S. Reeves, counsel for Defendant DANIEL SAMANIEGOCACHON, and hereby gives notice to the Court that he has a conflict with the status hearing re: psychological evaluation set before this Court on February 1, 2006, at 9:00 a.m. and requests that this Court continue the status hearing. Counsel is scheduled to begin trial in Maricopa County Superior Court before the Honorable L. Grant in the domestic relations matter of Monti and Monti, FC2004-005663, on February 1, 2006. It is estimated that the Monti trial will last approximately a week. 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 status conference. 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 date in the

Case 2:03-cr-01097-ROS

Document 138

Filed 01/30/2006

Page 1 of 2

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

above matter and extend the time for filing motions. Dated: January 30, 2006. /s/ MICHAEL S. REEVES, Attorney for Defendant SAMANIEGO-CACHON CERTIFICATE OF SERVICE I hereby certify that on this date, 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

2
Case 2:03-cr-01097-ROS Document 138 Filed 01/30/2006 Page 2 of 2