Free Motion to Continue - District Court of Arizona - Arizona

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DAVID M. OCHOA Attorney at Law P.O. Box 22126 Phoenix, AZ 85028 Tel: (602) 971-4048 Fax: (602) 956-2007 Bar #: 002163 [email protected] Attorney for Defendant Conant-Palafox UNITED STATES DISTRICT COURT

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DISTRICT OF ARIZONA
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United States of America,

) ) Plaintiff, ) ) vs. ) ) Benito Conant-Palafox, ) ) Defendant. ) ____________________________)

NO. CR02-193-PHX-FJM MOTION TO CONTINUE VIOLATION HEARING (2nd Request)

The defendant by and through his undersigned attorney respectfully moves the court
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for a continuance of the violation hearing set for September 24, 2007 The defendant needs
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additional time to prepare. Additionally, the defendant in CR07-837-PHX-FJM is charged
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will illegal reentry which alleged violation is the same basis for the violation of supervised
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release. The trial date in CR07-837-PHX-FJM is currently set for November 6, 2007. The
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defendant has also notified both the government and the court that the matter is ready to be
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set for a change of plea in CR07-837-PHX-FJM. For purposes of judicial economy it seems
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that both this case and the new case should be resolved together The government has no
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objections to the continuance.
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The defendant would request that the matter be set for November 6, 2007.
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It is expected that excludable delay under Title 18, U.S.C. Section 3161(h)(1)(F) may
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occur as a result of this motion or from an order based thereon.
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Respectfully submitted: August 17, 2007
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s/ David M. Ochoa
Case 2:02-cr-00193-FJM Document 39 Filed 08/17/2007 Page 1 of 2

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CERTIFICATE OF SERVICE I hereby certify that on this date, I electronically transmitted the attached document to the Clerk's Office using the CM/ECF System for filing and transmittal of Notice of Electronic Filing to the following CM/ECT registrants: AUSA Karen S. McDonald

Case 2:02-cr-00193-FJM

Document 39

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