Free Motion to Continue Dispositional Hearing - District Court of Arizona - Arizona

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ROBERT J. KAVANAGH Law Office of Robert J. Kavanagh, P.L.L.C. Bar No. 13573 51 West Elliot Road, Suite 109 Tempe, Arizona 85284 (480) 831-3040 [email protected] Attorney for Defendant IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA

UNITED STATES OF AMERICA, Plaintiff, -vsJOHN DAVID JOHNSON WHITE, Defendants. NO. CR-03-00550-001-PHX-FJM DEFENDANT WHITE'S MOTION TO CONTINUE VIOLATION HEARING (FIFTH REQUEST)

Defendant White, through undersigned counsel, moves this Court to enter an order continuing the currently set violation hearing date of October 2, 2007 for an additional thirtyfour days to November 5, 2007. The following reasons support Defendant's request for the continuance: 1. the Court recently appointed Defense counsel to represent Defendant; 2. potential defense witnesses need to be identified, interviewed, and possibly subpoenaed for the hearing; and 3. other investigative work needs to be completed. Defense counsel has conferred with Defendant White, and he has agreed to a continuance. Assistant U.S. Attorney Michael Lee has been contacted with regard to this motion and has no objection to the requested continuance.

Case 2:03-cr-00550-FJM

Document 147

Filed 08/30/2007

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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 LEE Assistant U.S. Attorney Two Renaissance Square 40 N. Central, Suite 1200 Phoenix, Arizona 85004-4408 CERTIFICATE OF SERVICE I certify that on August 30, 2007 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: Respectfully submitted this 30th day of August, 2007 s/ Robert J. Kavanagh Attorney for Defendant Defense counsel will be out of state on a preplanned vacation from November 17, 2007 through November 24, 2007. It is expected that excludable delay under Title 18 U.S.C. Section 3161(h)(8)(A) may occur as a result of this motion or from an order based thereon.

Case 2:03-cr-00550-FJM

Document 147

Filed 08/30/2007

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