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

Filing 967

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Cygnus Systems, Inc. v. Microsoft Corporation, et al Doc. 967 LAW OFFICES OF HARRIETTE P. LEVITT 1 1 4 7 NOR T H HOW A R D BOULEVARD TUCSO N , AR I Z O N A 85716 (520) 624-0400 FAX (520) 622-3308 e-mail: Bar No. 7077 Attorney for Defendant U N I T E D STATES DISTRICT COURT DISTRICT OF ARIZONA U N IT E D STATES OF AMERICA, ) ) P l a i n t if f , ) ) v s. ) ) CHARLES LEVOUGHT FLEMING, ) ) Defendant. ) ________________________________ ) N o . CR07-1836-TUC-CKJ(JCG) 1 st MOTION TO CONTINUE TRIAL E x c lu d a b le delay under 18 U.S.C. Section 3161 (H)(1)(f) will occur as a result of this m o tio n or of an order based thereon. C O M E S NOW the Defendant, CHARLES LEVOUGHT FLEMING, by and through h is attorney undersigned, and hereby moves this court to continue the trial of the above e n title d matter presently scheduled for December 26, 2007, and the plea deadline of D e c em b e r 14, 2007, for the reason that the parties are discussing a possible non-trial re so lu tio n of this case. Additionally, counsel requires additional time to properly prepare for tria in the event the matter is not resolved. A s s is ta n t U.S. Attorney Eric Markovich has no objection to this motion. This motion is made in good faith and not for purposes of delay but rather to maintain th e smooth and orderly administration of justice. R E S P E C T F U L L Y SUBMITTED this 20 th day of November, 2007. s/Harriette P. Levitt HARRIETTE P. LEVITT A tto rn e y for Defendant Copies of the foregoing delivered via ECF this 20 th day of November, 2 0 0 7 , to: E ric Markovich, Esq. A s s is ta n t U.S. Attorney 4 0 5 West Congress, Ste. 4800 T u c so n , AZ 85701-5040 a n d mailed to: C h a rle s Levought Fleming

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