Free Motion to Continue - District Court of Arizona - Arizona

1 JON M. SANDS Federal Public Defender 2 District of Arizona 3 850 W. Adams, Suite 201 Phoenix, Arizona 85007 4 Telephone: (602) 382-2749 5 KURT J. MAYER, VA #71830 Asst. Federal Public Defender 6 Attorney for Defendant 7 [email protected] 8 9 10 11 12 13 14 15 16 17 18 19 vs. (First Request) Juan Mario Cruz-Figueroa, Defendant. Juan Mario Cruz-Figueroa, through undersigned counsel, moves to continue the admit/deny hearing presently scheduled for August 28, 2007 for a period of at least sixty (60) days. Mr. Cruz-Figueroa has also been charged with Re-entry United States of America, Plaintiff, IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA No. CR-02-162-PHX-SRB MOTION TO CONTINUE ADMIT/DENY HEARING

20 After Deportation in violation 8 U.S.C. § 1326. This alleged illegal re-entry is the 21 basis for the petition to revoke Mr. Cruz-Figueroa's supervised release. The parties 22 are currently involved in negotiations to resolve both cases together. 23 Assistant U.S. Attorney, Raymond Woo, has been contacted and has no 24 25 26 ... 27 . . . 28 . . . objection to this requested continuance.

Case 2:02-cr-00162-SRB

Document 24

Filed 08/27/2007

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It is expected that excludable delay under Title 18 U.S.C. §

2 3161(h)(1)(F) may occur as a result of this motion or from an order based thereon. 3 4 5 6 7 8 9 Copy of the foregoing transmitted 10 by ECF for filing this 27th day 11 of August, 2007, to: 12 CLERK'S OFFICE United States District Court 13 Sandra Day O'Connor Courthouse 14 401 W. Washington Phoenix, Arizona 85003 15 RAYMOND WOO 16 Assistant U.S. Attorney United States Attorney's Office 17 Two Renaissance Square 18 40 N. Central Avenue, Suite 1200 Phoenix, Arizona 85004-4408 19 20 Copy mailed to: Respectfully submitted: August 27, 2007. JON M. SANDS Federal Public Defender s/Kurt J. Mayer KURT J. MAYER Asst. Federal Public Defender

JUAN MARIO CRUZ-FIGUEROA 21 Defendant 22
s/P.Muñoz

23 24 25 26 27 28

\ContAdmitDenyMTN

Case 2:02-cr-00162-SRB

Document 24

Filed 08/27/2007

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