Free Motion to Continue - District Court of Arizona - Arizona

1 JON M. SANDS Federal Public Defender 2 District of Arizona 3 850 W. Adams Street, Suite 201 Phoenix, Arizona 85007 4 Telephone: (602) 382-2755 5 DOUGLAS A. PASSON, # 017423 [email protected] 6 Asst. Federal Public Defender Attorney for Defendant 7 IN THE UNITED STATES DISTRICT COURT 8 9 10 11 12 13 14 15 16 17 18 19 20 vs. Juan Garcia-Aguilar, Defendant. United States of America, Plaintiff, DISTRICT OF ARIZONA CR-02-371-PHX-SMM MOTION TO CONTINUE ADMIT/DENY HEARING (First request)

Defendant Juan Garcia-Aguilar, through undersigned counsel, moves this Court to continue the Admit/Deny Hearing, currently scheduled for Monday, July 17, 2006, for a period of thirty (30) days. Mr. Garcia-Aguilar is currently accused of a new violation of 8 U.S.C.

21 § 1326 in cause number CR-06-0622-PHX-EHC. Said matter is set for trial on 22 August 15, 2006. The government has conveyed a plea offer that encompasses the 23 new charge and also the disposition of the supervised release violation. Should the 24 defendant proceed with this resolution, it serves the interests of judicial economy to 25 26 27 28 consolidate the admit/deny and disposition proceedings with the change of plea and sentencing in the new cause number.

Case 2:02-cr-00371-SMM

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Defense counsel has contacted the Assistant U.S. Attorney assigned to

2 this case, Raynette Logan, with regard to this motion. Ms. Logan indicates that she 3 makes no objections to the requested continuances. 4 5 6 7 8 9 10 11 12 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. Respectfully submitted this 14th day of July 2006. JON M. SANDS Federal Public Defender s/ Douglas A. Passon DOUGLAS A. PASSON Asst. Federal Public Defender

transmitted 13 Copy of the foregoing this 14th day by CM/ECF for filing 14 of July 2006 to: 15 Clerk's Office United States District Court 16 Sandra Day O'Connor Courthouse 401 W. Washington 17 Phoenix, Arizona 85003 18 Raynette Logan 19 Assistant U.S. Attorney United States Attorney's Office 20 Two Renaissance Square 40 N. Central Avenue, Suite 1200 21 Phoenix, Arizona 85004-4408 22 Copy mailed to: 23 Juan Garcia-Aguilar 24 Defendant 25 27 28 2 s/ Douglas A. Passon 26 Douglas A. Passon

Case 2:02-cr-00371-SMM

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