Motion Picture Association of America v. CrystalTech Web Hosting Inc.

Filing 100

Motion Picture Association of America v. CrystalTech Web Hosting Inc.

Doc. 100

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Law Office of Wanda K. Day
Box 86840 Tucson, Arizona 85754 AZ Bar No. 012684 [phone] UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA UNITED STATES OF AMERICA, ) ) C R­09-0482-TUC-RCC-CRP Plaintiff, ) ) MOTION TO CONTINUE v. ) ) TRIAL AND OTHER DATES ) ALEJANDRO BOJORQUEZ-HERNANDEZ ) ) ( Unopposed) ) Defendant. ) (First Request by Undersigned) ) 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, ALEJANDRO BOJORQUEZ-HERNANDEZ, through counsel, respectfully requests this Court to continue the plea deadline, trial and all other dates presently set in this case for approximately thirty (30) days from the current trial date of June 2, 2009. Counsel needs a reasonable amount of time to prepare for trial as she exercises due diligence to prepare for trial. (18 USC 3161(h)(8)(B)(iv)) Assistant United States Attorney Joseph Hanley has no objection to the continuance. Also the defendant does not object to a continuance. This is the first 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. RESPECTFULLY SUBMITTED: May 27, 2009. LAW OFFICE OF WANDA K. DAY ___/s/__Wanda K. Day Wanda K. Day

Dockets.Justia.com

1 2 3 4 5 6 Copy of the foregoing 7 Motion and proposed Order mailed/delivered by 8 ECF to: 9 ­ Joseph Hanley, Esq., AUSA 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

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