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

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MARK PAIGE 45 West Jefferson Luhrs Tower - Suite #806 Phoenix, AZ 85003-2317 (602) 254-5457 State Bar #020902 [email protected] Attorney for Defendant

UNITED STATES DISTRICT COURT 7 8 9 10 11 12 13 14 The defendant, Jesse Moore, by and through counsel respectfully moves the Court for a 15 continuance of the presently set trial date of February 6, 2007 and extension of the deadline for 16 pretrial motions on the following grounds: 17 1. The defendant is charged by Indictment with murder. The defendant was previously 18 indicted and tried. After conviction and sentencing an appeal was filed and heard by the 19 Ninth Circuit. As a result of that appeal this matter was remanded for a new trial. 20 Undersigned counsel was appointed on or about January 4, 2007. 21 2. Counsel has been advised as to the enormous size of the file. Counsel has received 22 approximately 6 boxes of materials from appellate counsel. Counsel has been advised by 23 prior trial counsel that the volume of material possessed at his office relating to the 24 investigation, discovery, research, experts, evaluations and other matters is very 25 extensive. Counsel will be making arrangements to review the file(s) and determine how 26 to proceed. 27 3. Consequently, counsel is requesting that this matter be continued for at least 6 months 28 DISTRICT OF ARIZONA _______________________________________ ) UNITED STATES, ) No.: CR-03-764-PHX-JAT ) Plaintiff, ) ) DEFENDANT'S MOTION TO v. ) CONTINUE TRIAL AND EXTEND ) PRETRIAL MOTIONS AND ALL Jesse Moore, ) OTHER DEADLINES ) Defendant. ) (First Request) _______________________________________)

Case 2:03-cr-00764-JAT

Document 1183

Filed 01/16/2007

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to permit counsel to attempt to prepare for the defense of this defendant. 4. This defendant is in custody. At the time of this filing, counsel for the Government, Kurt Altman, has no objection to this request. The defendant requests a continuance of this matter for at least six (6) months to allow undersigned counsel to be prepared and able to render effective assistance of counsel consistent with the Sixth Amendment guarantee for every defendant.

Respectfully submitted this 16th day of January, 2007. S/ Mark A. Paige MARK PAIGE Attorney for Defendant I hereby certify that on January 16, 2007, I electronically transmitted the attached 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: Kurt Altman Assistant U.S. Attorney [email protected] S/ Mark A. Paige Mark A. Paige

Case 2:03-cr-00764-JAT

Document 1183

Filed 01/16/2007

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