Free Motion to Continue Change of Plea Hearing - District Court of Arizona - Arizona

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TYRONE MITCHELL, P.C. Tyrone Mitchell, Esq., No. 016267 2633 East Indian School Road, Suite 320 Phoenix, Arizona 85016 Telephone: (602) 956-8200 Facsimile: (602) 956-8201 IN THE UNITED STATES DISTRICT COURT

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DISTRICT OF ARIZONA UNITED STATES OF AMERICA., Plaintiff, vs. JUAN CARLOS CASTANEDA, MALDONADO) ) ) ) ) ) ) ) ) ) No. CR 03-0465-001-PHX-JAT

MOTION TO CONTINUE ADMIT/DENY HEARING (First Request)

Defendant. _____________________________________

DEFENDANT JUAN CARLOS MALDONADO-CASTANEDA, by and through undersigned counsel, respectfully moves this Honorable Court for an Order continuing the hearing

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for JUAN CARLOS MALDONADO-CASTANEDA, scheduled for February 25, 2008. The government is going to charge the defendant with illegal re-entry. The defendant wants to resolve both cases at the same time. Further, defense counsel begins a two-week trial before the Honorable David Bury in Tucson , Arizona in State v. Corbett, Cr 2007-1508 on February 25, 2008

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, the same day set for hearing in this case. Motions hearing are scheduled for February 25, 2008. Undersigned counsel avows that he has contacted the Assistant United States Attorney assigned to this matter, Darcy Cerow regarding her position to this motion and Ms. Cerow does Case 2:03-cr-00465-JAT Document 21 Filed 02/25/2008 Page 1 of 4

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not have any objection the relief being requested herein. This Motion is made in good faith and will serve the public's interest in that providing Defendant an opportunity to finish his cooperation with the government. THEREFORE, based on the foregoing, Defendant JUAN CARLOS MALDONADOCASTANEDA, by and through undersigned counsel, respectfully requests that this Honorable Court enter an Order continuing the hearing set February 25, 2008, to a date subject to the Court's

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calendar. RESPECTFULLY SUBMITTED this 25 th day of February 2008. TYRONE MITCHELL, P.C.

By

/s/ Tyrone Mitchell Tyrone Mitchell Attorneys for Defendant

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CERTIFICATE OF SERVICE I certify that on the 25 th day of February, 2008, 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. Darcy Cerow, Esq. Assistant U.S. Attorney Two Renaissance Square 40 North Central Avenue Suite 1200 Phoenix, Arizona 85004-4408

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