MDY Industries, LLC v. Blizzard Entertainment, Inc. et al

Filing 180

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MDY Industries, LLC v. Blizzard Entertainment, Inc. et al Doc. 180 LAW OFFICES OF THOMAS JACOBS 271 North Stone Avenue Tucson, Arizona 85701 PHN: (520) 628-1622 FAX: (520) 628-4534 Thomas Jacobs, Esq. State Bar No. 013275 P.C.C. No. 64489 Attorney for: Defendant. UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA UNITED STATES OF AMERICA Plaintiff, v. MANUEL J. GUERRERO-RAMIREZ, Defendant. ) ) ) ) ) ) ) ) ) ) ) No. CR07-0795-03-TUC-CKJ-GEE MOTION TO CONTINUE PLEA DEADLINE AND TRIAL DATES [1st REQUEST] It is expected that excludable delay under Title 18, United States Code, Section 3161(h)(3)(B)(8)(A) will occur as a result of this Motion or of an order based thereon. Defendant, MANUEL JAVIER GUERRERO-RAMIREZ, by and through his attorney, hereby moves this court for a 30 day continuance of the Plea Deadline presently scheduled for June 22, 2007, at 3:00 p.m., and Trial date presently scheduled for July 3, 2007, at 9:30 a.m., for the following reasons: 1. Defendant's counsel needs additional time to prepare for Trial. 1 2. 3. 4. The parties are still discussing a possible non-trial disposition. The Government, per Assistant U.S. Attorney, Patrick Barry, and defense counsel for co-defendants have no objection to this requested continuance. Pursuant to Local Rule 1.10(n), Defendant hereby advises the court that this is the first requested extension. RESPECTFULLY SUBMITTED this 14th day of June, 2007. LAW OFFICES OF THOMAS JACOBS By Thomas Jacobs, Esq. Attorney for Defendant Copy delivered electronic or other means to: The Honorable Cindy K. Jorgenson Email: AUSA Patrick Barry Email: 2 3

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