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

Filing 286

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Hortencia Delgadillo, Esq. P.O. Box 844 Tucson, Arizona 85702 Telephone: (520) 498-4913 State Bar No. 010595 Attorney for: Defendant MARIO JUAREZ-RAMIREZ IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA UNITED STATES OF AMERICA, Plaintiff, vs. MARIO JUAREZ-RAMIREZ, Defendant. Defendant MARIO No. CR06-O1124-TUC-CKJ(JJM) (AMENDED) SECOND MOTION TO CONTINUE TRIAL DATE AND OTHER RELATED DATES AND DEADLINES (By Defendant) JUAREZ-RAMIREZ, through undersigned counsel, moves the Court to vacate the trial date in this case that is currently set for October 24, 2006, as well as all other related dates and deadlines, including the Plea Deadline date, pursuant to 18 U.S.C. 3161(h)(8)(A) and (B)(iv). Defendant further moves this Court to continue the trial date for a period of 30 days and set the new trial date as soon as practicable following November 23, 2006, and requests that this Court reset the dates for submission of Motions and Plea Deadline accordingly, for the reasons set forth below. This is Defendant's second request for a continuance. Defendant requests a continuance for the following reasons: 1. Defendant requires additional 1 time to prepare for UNITED STATES v. MARIO JUAREZ-RAMIREZ, CR06-01124-TUC-CKJ (JJM) 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 trial. Defendant expects to resolve this matter through a non-trial However, in the event the anticipated resolution does disposition. not occur, Defendant requests 30 days in order to allow defense counsel sufficient time for trial preparation. 2. Additional time for this purpose will serve the interests of justice and judicial economy. 3. The Government, through AUSA Irene Feldman, has no objection to the requested continuance. Excludable delay under 18 U.S.C. 3161(h)(1)(F) and (8)(A) will occur as a result of this motion and any order based thereon. Pursuant to 18 U.S.C. 3161(h)(8)(A), Defendant, through counsel, hereby waives any speedy trial issues resulting from this requested continuance from the date this motion is filed through the date on which the case is tried. DATED this 17th day of October 2006. S/Hortencia Delgadillo HORTENCIA DELGADILLO Attorney for Defendant Original of the foregoing filed by ECF this 17th day of October 2006 with: Clerk of the Federal District Court 405 W. Congress, Suite 1500 Tucson, AZ 85701 UNITED STATES v. MARIO JUAREZ-RAMIREZ, CR06-01124-TUC-CKJ (JJM) 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Copy of the foregoing delivered electronically this 17th day of October 2006 to: Hon. Cindy K. Jorgenson United States District Court Judge 405 W. Congress Tucson, Arizona 85701 Irene Feldman Assistant U.S. Attorney Office of the United States Attorney 405 W. Congress, Suite 4800 Tucson, Arizona 85701 UNITED STATES v. MARIO JUAREZ-RAMIREZ, CR06-01124-TUC-CKJ (JJM) 3

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