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

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BALTAZAR INIGUEZ Attorney at Law 3106 N. 16th Street Phoenix, AZ 85016-7610 Phone (602) 285-5688 Fax (602) 277-1636 [email protected] State Bar No. 006084 Attorney for Defendant UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA ) ) Plaintiff, ) ) vs. ) ) Francisco Javier Andrade-Martinez, ) ) ) Defendant. ) ) United States of America, No. CR 00-1186-PHX-SMM

MOTION TO CONTINUE TRIAL AND EXTEND TIME FOR FILING MOTIONS

(1ST Request)

COMES NOW Defendant Francisco Javier Andrade-Martinez, by and through his undersigned attorney, and respectfully requests this Court to continue the trial date set on April 4, 2006 for sixty (60) days and vacate the status conference now set on March 20, 2006 at 2:00 p.m. for the reason that discovery and trial preparation are ongoing. Let the Court be advised that the Assistant U.S. Attorney does not object to

Case 2:00-cr-01186-SMM

Document 136

Filed 03/13/2006

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a continuance in this matter. It is expected 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. RESPECTFULLY SUBMITTED this 13th of March, 2006.

s/Baltazar Iniguez BALTAZAR INIGUEZ Attorney for Defendant Andrade-Martinez CERTIFICATE OF SERVICE

I hereby certify that on this date, I electronically transmitted the attached documents to the Clerk's Office using the CM/ECF System for filing and 15 transmittal of Notice of Electronic filing to the following CM/ECF registrants: 16 Brian Larson.
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Case 2:00-cr-01186-SMM

Document 136

Filed 03/13/2006

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