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

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Darius M. Nickerson BURNS, NICKERSON & TAYLOR, PLC 111 W. Monroe, Suite 1500 Phoenix, AZ 85003 (602) 254-0004 Bar #010078 Attorney for Defendant

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA United States of America, Plaintiff, vs. John D. Johnson White, Defendant ) CR-03-00550-001-PHX-FJM ) ) ) MOTION TO CONTINUE ) VIOLATION HEARING ) ) (Second Request) ) ) )

Defendant, John D. Johnson White, by and through undersigned counsel, hereby
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moves this Court to enter an order continuing the currently set violation hearing date of
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April 3, 2007, for sixty days. A Motion has also been filed to continue the trial date in CR-06-1073-PHX-FJM. The reason for this requested continuance is based upon recent information that there are two additional supplemental investigative reports which the parties do not have. In addition the fingerprint analysis has not been completed. Therefore, Defendant moves this court to continue the currently set trial date of April 3, 2007 for sixty days.

Case 2:03-cr-00550-FJM

Document 137

Filed 03/23/2007

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The Assistant United States Attorney, Michael Lee, has been contacted regarding this motion and has no objection to this requested continuance. In addition he has also expressed an attitude of cooperation regarding discovery issues. Excludable delay under 18 U.S.C. §3161(h)(8)(A) will occur as a result of this motion or of an order based thereon. RESPECTFULLY SUBMITTED this day of March 2007

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s/ Darius M. Nickerson Darius M. Nickerson BURNS, NICKERSON & TAYLOR, PLC

Copies of the foregoing filed Via ECM/EF this _____ day of March 2007, to: Sandra Day O'Connor U.S. Courthouse United States District Court Honorable Frederick J. Martone 401 West Washington Phoenix, AZ 85003 Michael Lee Assistant U.S. Attorney 40 North Central Ave., Ste. 1200 Phoenix, AZ. 85004

Case 2:03-cr-00550-FJM

Document 137

Filed 03/23/2007

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