Ecommerce Innovations L.L.C. v. Does 1-10

Filing 67

Ecommerce Innovations L.L.C. v. Does 1-10

Doc. 67

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Law Office of Wanda K. Day
Box 86840 Tucson, Arizona 85754 Pima Computer No. 13190 AZ Bar No. 012684 [phone] UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA UNITED STATES OF AMERICA, Plaintiff, v. ELBER ZAVALA-GUTIERREZ, Defendant. ) ) ) ) ) ) ) ) ) ) ) ) CR­07-0622 - TUC-CKJ-GEE MOTION TO CONTINUE TRIAL AND OTHER DATES ( Unopposed) (Second Request)

It is expected that excludable delay under Title 18, United States Code, §3161(h)(8)(B)(iv) will occur as a result of this motion or an order based thereon. Defendant, ELBER ZAVALA-GUTIERREZ, through counsel, respectfully requests this Court to continue the plea deadline, trial and all other dates presently set in this case for approximately forty-five (45) days from the current trial date of July 31, 2007. Counsel needs a reasonable amount of additional time to effectively prepare for trial as she exercises due diligence in the preparation of the case for trial. (18 USC 3161(h)(8)(B)(iv)) Assistant United States Attorney Claire Lefkowitz has no objection to the continuance. Also, the defendant does not object to a continuance. This is the second request for continuance by undersigned counsel. It is expected that excludable delay under Title 18, United States Code, §3161(h)(1)(F) will occur as a result of this motion or an order based thereon.

Dockets.Justia.com

1 2 3 4 5 6 7 8 9 10 11 12 Copy of the foregoing 13 Motion and proposed Order mailed/delivered to: 14 ­ Claire Lefkowitz, Esq., AUSA 15 16 17 18 19 20 21 22 23 24 25 26 27 28 RESPECTFULLY SUBMITTED: July 13, 2007. LAW OFFICE OF WANDA K. DAY ___/s/__Wanda K. Day Wanda K. Day

Law Office of Wanda K. Day
Box 86840 Tucson, Arizona 85754 Pima Computer No. 13190 AZ Bar No. 012684 [phone]