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

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ANNE M. WILLIAMS, P.C. ANNE M. WILLIAMS # 012414 Attorney at Law 1833 East Baseline Road PMB 265 Gilbert, Arizona 85233-1545 [email protected] (T) 480.892.7177 (F) 480.471.6652 Attorney for Marvin Jermain Errol Burnet

IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA

United States of America, CR 03-00470-005-PHX-SRB Plaintiff, v. MOTION TO CONTINUE TRIAL, EXTEND TIME TO FILE PRETRIAL MOTIONS

MARVIN JERMAIN ERROL BURNET, Defendant. (FIRST REQUEST)

DEFENDANT, MARVIN JERMAIN ERROL BURNET, through undersigned counsel, 19 20 21 22 23 24 25 26 each document read to Mr. Burnet in Dutch, and advising Mr. Burnet about the American 27 28 Justice System. moves this Court to continue the trial date of February 6, 2007, for an additional ninety (90) days. Mr. Burnet requests additional time to attempt to conduct further investigation and/or prepare for trial. Mr. Burnet is from Amsterdam and his primary language is Dutch. Therefore, most contact with Mr. Burnet will involve more time than usual when dealing with clients due to the necessity of arranging for the Dutch Interpreter (once one becomes known to counsel), having

Case 2:03-cr-00470-SRB

Document 156

Filed 01/06/2007

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The defendant further requests this Court extend time to file pretrial motions for an additional sixty (60) days. Assistant U.S. Attorney, Ms. Mary Beth Pfister, has been contacted with regard to this motion and has no objection to the requested continuance.

5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Ms. Mary Beth Pfister [email protected] Assistant U.S. Attorney Courtesy Copy of this motion provided via e-mail attachment to: Honorable Susan R. Bolton [email protected] /s/ ANNE M. WILLIAMS ANNE M. WILLIAMS, P.C. Respectfully submitted: January 6, 2007. It is expected that excludable delay under Title 18 U.S.C. Section 3161(h)(1)(F) may occur as a result of this motion or from an order based thereon.

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Case 2:03-cr-00470-SRB

Document 156

Filed 01/06/2007

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