Free Motion to Continue - 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 ) ) (First 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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February 6, 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 that there is continuing investigation and discovery. The Assistant United States Attorney, Michael Lee, has been contacted regarding this motion and has no objection to this requested continuance.

Case 2:03-cr-00550-FJM

Document 134

Filed 01/19/2007

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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. Therefore, Defendant moves this court to continue the currently set trial date of February 6, 2007 for sixty days. RESPECTFULLY SUBMITTED this 19th day of January 2007

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

Copies of the foregoing filed Via ECM/EF this 19th day of January 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

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Case 2:03-cr-00550-FJM

Document 134

Filed 01/19/2007

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