Cygnus Systems, Inc. v. Microsoft Corporation, et al

Filing 128

Cygnus Systems, Inc. v. Microsoft Corporation, et al

Doc. 128

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J O N M. SANDS Fe d e ra l Public Defender 2 D is tric t of Arizona 2 2 8 5 S. 4 th Ave., Suite E 3 Y uma , AZ 85364 T e le p ho ne : [phone]
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M A T T H E W A. JOHNSON C a . State Bar No. 207984 6 m a t t h e w _ j o h n s o n @ fd . o r g A s s t. Federal Public Defender 7 A tto rne y for Defendant
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IN THE UNITED STATES DISTRICT COURT D IS T R IC T OF ARIZONA U nite d States of America, Plaintiff, v. J ua n Cruz-Castellanos, Defendant. N O . 07-1086M D E F E N D A N T 'S MOTION TO E X T E N D TIME TO INDICT (F ir s t Request) (Unopposed) (R e e ntry After Deportation)

T h e above-named defendant, Juan Cruz-Castellanos, who is accused of R e e ntry After Deportation in violation of 8 U.S.C. § 1326, being advised of the nature of the charges and of his rights in this matter, hereby moves this Court, pursuant to 18 U.S.C. § 3161(h)(8)(A), for an extension of an additional thirty (30) days within which the G o ve r n m e n t must indict this matter as required by the Speedy Trial Act. 18 U.S.C. § 3 1 6 1 . The basis for this request is to permit the defendant time within which to review the fa c ts in this matter, to review discovery and to investigate defenses prior to waiving rights to a number of hearings. The government has made a plea offer in this matter and will withdraw this o ffe r if not timely accepted before this matter is indicted. Thereafter, a plea offer, if any, w ill be less favorable to the defendant.

Dockets.Justia.com

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Fo r the foregoing reasons, the defendant asserts that the ends of justice will b e served by continuing for thirty (30) days the speedy indictment date and those ends o utw e igh the best interests of the public and those of the defendant. Counsel for the go ve rnme nt has been consulted and does not object. Excludable delay under 18 U.S.C. § 3161(h)(8)(A) and (h)(1)(F) may result fro m this motion or from an order based thereon. R e s p e c tfully submitted this January 24, 2007. J O N M. SANDS Fe d e ra l Public Defender

s/Matthew Johnson
MATTHEW JOHNSON A s s t. Federal Public Defender

I hereby certify that on January 24, 2007, I electronically transmitted the attached document to the Clerk's Office using the ECF System for filing and transmittal to the 15 following ECF registrants:
TIMOTHY ANDREWS A s s is ta nt United States Attorney 17 4 0 3 5 S. Avenue A Y uma , Arizona 85365
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C o p y mailed to: D e fe n d a n t