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 Ortega-Saavedra UNITED STATES DISTRICT COURT

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DISTRICT OF ARIZONA
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United States of America,

) ) Plaintiff, ) ) vs. ) ) Jose Luis Ortega-Saavedra, ) ) Defendant. ) ____________________________)

NO. CR00-950-PHX-RCB MOTION TO CONTINUE ADMIT/ DENY HEARING (1st Request)

The defendant by and through his undersigned attorney respectfully moves the court
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for a continuance of the admit/deny hearing set for July 23, 2007
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The defendant needs

additional time to prepare. Undersigned counsel has learned that the government will be filing new charges of illegal reentry after deportation. For purposes of judicial economy it
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seems that both this case and the new case should be resolved together The government has
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no objections to the continuance.
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The defendant would request at least a 60 continuance.
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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: July 9, 2007
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s/ David M. Ochoa
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Case 2:00-cr-00950-DGC

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Filed 07/09/2007

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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 Lisa J. Settel

Case 2:00-cr-00950-DGC

Document 29

-2Filed 07/09/2007

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