Free Motion to Continue - District Court of Arizona - Arizona

JERRY HERNANDEZ ATTORNEY AT LAW BAR #13021 115 W. HU-ESTA DR. TEMPE, AZ 85282 (480) 231-3053 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA

UNITED STATE OF AMERICA, Plaintiff, vs. MARIO AGUILAR Defendant.

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No. CR-02-00147-002-PHX-ROS (Assigned to the Honorable Roslyn Silver) MOTION TO CONTINUE TRIAL AND PRETRIAL MOTIONS (Second Request)

Defendant, Mario Aguilar, by and through undersigned counsel, hereby moves the Court to enter an order continuing the currently scheduled trial date of September 6, 2005, and to extend the deadline for filing pretrial motions pursuant to Rule 12, Federal Rules of Criminal Procedure; 18 U.S.C. §3161; and the 4th, 5th, 6th, 8th, and 14th Amendments to the United States Constitution. Defense counsel needs additional time to investigate the case, prepare any pretrial motions, prepare for trial, and render the effective assistance of counsel to the defendant. Defendant requests a continuance of ninety days. United States Attorney, Andrew Pacheco agrees to this continuance.

Case 2:02-cr-00147-ROS

Document 55

Filed 08/17/2005

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Excludable delay under 18 U.S.C. §3161 (h)(8)(A) and (h)(1)(F) may result from this motion or from an order issued pursuant to the motion.

Respectfully submitted: August 18, 2005

s/ JERRY HERNANDEZ 115 W. Hu-Esta Dr. Tempe, Arizona 85282 BAR #13021

Copy of the foregoing mailed/ Delivered this 18th day of August, 2005, to:

Andrew Pacheco Assistant United States Attorney Copy Mailed to: Mario Aguilar Defendant

Case 2:02-cr-00147-ROS

Document 55

Filed 08/17/2005

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