Free Motion to Continue Arraignment - District Court of Arizona - Arizona

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Michael B. Bernays State Bar # 007057 111 West Monroe Phoenix, AZ 85003 (602) 254-5544 Attorney for Defendant

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UNITED STATED DISTRICT COURT
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DISTRICT OF ARIZONA UNITED STATES OF AMERICA Plaintiff, vs. SHEILA M. ISABELL, Defendant ) ) ) ) ) ) ) ) Case No.: CR 03-1082-001-PHX-MHM

MOTION TO CONTINUE ARRAIGNMENT

The Defendant, Sheila Isabell, through counsel, Michael B. Bernays, hereby moves the Court to continue the Arraignment currently scheduled for March 14, 2006 at 3:00 p.m., on the grounds that Ms. Isabell, who resides in Chillicothe, Ohio was served with a summons for this Arraignment on Monday March 6, 2006. Ms. Isabell is indigent and on Social Security disability for back pain and depression, and is without the means to travel to Arizona on her own. Counsel is exploring options of finding assistance for Ms. Isabell to come for her arraignment, but will not be able to make such arrangement in time for Ms. Isabell's appearance on March 14, 2006. Counsel has spoken with Assistant United States Attorney John Lopez, who has authorize counsel to state that the government does not oppose this motion. For all the forgoing reasons, counsel would request the court to grant the motion to continue and continue the arraignment date for approximately 30 days.

Case 2:03-cr-01082-MHM

Document 25

Filed 03/09/2006

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Excludable delay pursuant to 18 USC § 3161(h)(8)(A) will occur as a result of this motion.
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RESPECTFULLY SUBMITTED this day of March, 2006.
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s/ Michael B. Bernays Michael B. Bernays 111 West Monroe Phoenix, AZ 85003 Attorney for Defendant

Copy of the foregoing e-mailedVia EFC this 9th day of March, 2006, to: John Lopez Assistant U.S. Attorney 40 North Central Avenue, Ste. 1200 Phoenix, AZ 85004-4408 By: s/ Michael B. Bernays

Case 2:03-cr-01082-MHM

Document 25

Filed 03/09/2006

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