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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 Defendant is currently undergoing a court-ordered psychological evaluation and more time is necessary for testing and evaluation. Counsel would suggest that a 60-day continuance would benefit this process. 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. ยง3161(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.
Case 2:03-cr-01097-ROS
Document 126
Filed 11/14/2005
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Dated: November 14, 2005. /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
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Case 2:03-cr-01097-ROS Document 126 Filed 11/14/2005 Page 2 of 2