Free Motion to Continue - District Court of Arizona - Arizona

TYRONE MITCHELL, P.C. Tyrone Mitchell, Esq., No. 016267 1700 North Seventh Street, Suite 3 Phoenix, Arizona 85006 Telephone: (602) 258-5749 Facsimile: (602) 258-5233 Attorneys for Defendant IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA UNITED STATES OF AMERICA., Plaintiff, vs. ELNORA THOMAS, Defendant. _____________________________________ ) ) ) ) ) ) ) ) ) ) No. CR 03-1090-PHX-DKD MOTION TO CONTINUE ADMIT/HEARING (First Request)

DEFENDANT ELNORA THOMAS, by and through undersigned counsel, respectfully moves this Honorable Court for an Order continuing the Admit/Deny date presently scheduled for August 10, 2006 for a period of seven (7) days subject to the Court's calendar and for the foregoing reasons. Defense counsel is scheduled to be out of town on a case in the District of Pennsylvania on August 10 and 11. The case is before the Honorable Roslyn Silver and is sealed.

Case 2:03-cr-01090-DKD

Document 56

Filed 08/06/2006

Page 1 of 3

Undersigned counsel avows that he has contacted the Assistant United States Attorney assigned to this matter, Joe Koehler regarding his position to this motion and Mr. Koehler does not have any objection the relief being requested herein. This Motion is made in good faith and will serve the public's interest in that providing Defendant with effective representation is necessary to insure fairness and protect the Defendant's constitutional rights. THEREFORE, based on the foregoing, Defendant ELNORA THOMAS, by and through undersigned counsel, respectfully requests that this Honorable Court enter an Order extending the time for the Admit/Deny hearing for a period of seven (7) days.

RESPECTFULLY SUBMITTED this 6 th day of August, 2006. TYRONE MITCHELL, P.C.

By

/s/ Tyrone Mitchell Tyrone Mitchell Attorneys for Defendant

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CERTIFICATE OF SERVICE I certify that on the 6 TH day of August, 2006, I electronically transmitted this document to the Clerk's Office using the CM/ECF system for filing and transmittal of a Notice of Electronic Filing to the following CM/ECF registrants. Joe Koehler , Esq. Assistant U.S. Attorney Two Renaissance Square 40 North Central Avenue Suite 1200 Phoenix, Arizona 85004-4408

/s/ Tyrone Mitchell Tyrone Mitchell Attorneys for Defendant

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