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

Filing 1508

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Motion Picture Association of America v. CrystalTech Web Hosting Inc. Doc. 1508 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 DAVID VALADEZ Attorney at Law 177 N. Church Ave., Ste 200 Tucson, Arizona 85701 Phone: (520) 628-7777 Fax: (520) 298-3154 State Bar No. 18175 Attorney for Defendant IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA UNITED STATES OF AMERICA, Plaintiff, vs. JAIME MORENO-VILLALOBOS et al, Defendant. ) No. CR07-0740-004-TUC-CKJ(HCE) ) ) MOTION TO CONTINUE: ) ) MOTIONS DEADLINE: PLEA ) DEADLINE; TRIAL DATE ) ) [FIRST DEFENSE REQUEST] ) ) ) ) ) It is expected that excludable delay pursuant to 18 U.S.C. 3161 (h)(1)(F) may occur as a result of this motion or from an order based thereon. COMES NOW the Defendant, JAIME MORENO-VILLALOBOS, by and through his attorney undersigned and hereby moves this Court for a continuance of the Motions Deadline date, Plea Deadline date and Trial date. The plea deadline is currently scheduled for August 10, 2007 and the Trial for August 28, 2007. Counsel undersigned requests a continuance of at least (45) days for the following reasons: 1. Counsel needs additional time to prepare for trial; 2. Assistant United States Attorney, Shelly Clemens, has been advised of this motion and has no objection to this continuance. 3. All Counsel for co-defendants have been contacted and there have been no objections to this motion to continue. -1- 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 The Court is urged to find that circumstances exist which require VACATING the current pre-trial dates and GRANTING a continuance and respectfully urges the Court to Make the following findings: 1. That this request for a continuance is made in the interests of justice and not simply for the purposes of delay. 2. That the Court find extraordinary circumstances exist and that the interest of justice requires the pre-trial dates in this matter be continued. 3. Defendant would waive any speedy trial time limits. Based on the foregoing, Defense Counsel respectfully requests the scheduled dates be VACATED and a continuance GRANTED. DATED this 31st day of July, 2007. s/David R. Valadez DAVID R. VALADEZ Attorney for Defendant Copy of the foregoing delivered this date to: Shelly Clemens, AUSA Greta Vietor, Counsel for Enriquez-Hernandez Thomas Hippert, Counsel for Aguilera-Cortez Kevin Lerch, Counsel for Hernandez-Padilla Alfred Islas, Ccounsel for Martinez-Duenas -2-

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