Motion Picture Association of America v. CrystalTech Web Hosting Inc.
M o t i o n Picture Association of America v. CrystalTech Web Hosting Inc.
D o c . 651
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THE LAW OFFICE OF STEPHANIE K. BOND, P.C. P.O. Box 1082 Tucson, Arizona 85702 Telephone: (520) 624-2636 Facsimile: (520) 623-1716 email@example.com State Bar No. 19000 I N THE UNITED STATES DISTRICT COURT F O R THE DISTRICT OF ARIZONA U n ite d States of America, P l a i n t i f f, v. M ic h a e l Dee Pulsipher, D efe n d a n t. ) ) ) ) ) ) ) ) ) ) C a s e No. CR-08-1463-TUC-RCC-GEE M O T I O N TO EXTEND PLEA D E A D L I N E AND CONTINUE T R I A L DATE ( S e c o n d Request)
It is expected that excludable delay under Title 18, United States Code, 14 § 3 1 6 1 (h )(8 )(A ) will occur as a result of this motion or an order based thereon. 15 D e f en d a n t Michael Dee Pulsipher , through counsel, requests a 60-day continuance 16 o f the Plea Deadline set for November 13, 2009 and the Trial set for December 1, 2009. 17 This request for continuance is made for the following reasons: 18 1) 19 2) 20 21 R E S P E C T F U L L Y SUBM I T T E D : November 6, 2009 22 23 24 25 26 27 C o p y to: 28 Karen Rolley, A s s is ta n t United States Attorney s /S te p h a n ie K. Bond Stephanie K. Bond T h e Law Offices of Stephanie K. Bond, P.C. A s s is ta n t United States Attorney, Karen Rolley h a s no objection to this continuance. Additional time is needed for trial preparation.
1 2 3 4 5 I N THE UNITED STATES DISTRICT COURT 6 F O R THE DISTRICT OF ARIZONA 7 U n ite d States of America, 8 P l a i n t i f f, 9 v. 10 M ic h a e l Dee Pulsipher, 11 D e f e n d a n t s. 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 R e : Continuance of trial. T h is matter is presently set for trial on December 1, 2009. T h e defendant having filed a motion to continue and for reasons set forth therein, a d d itio n a l time is necessary for pre-trial investigation. The government has no objection to a continuance. The Court finds that the ends of justice served by granting a continuance outweigh th e best interests of the public and the defendant in a speedy trial because failure to grant th e continuance is likely to result in a miscarriage of justice if the defendant is required to g o to trial on the present trial date because of the reasons set forth hereinbefore. IT IS ORDERED as follows: 1. The deadline for a plea in this case is: . ) ) ) ) ) ) ) ) ) ) C R 09-1463-TUC-RCC-GEE
Counsel will not be reminded by the Court of this plea deadline and the deadline will be s tric tly enforced. THE PLEA MUST BE TAKEN BEFORE THE MAGISTRATE JUDGE ON OR BEFORE THE PLEA DEADLINE. 2. T h a t this matter is RESET for trial on:
at 9:30 a.m. Counsel are to be present at 9:00 a.m. 3. E x c lu d a b le delay under 18 U.S.C. §3161(h)(8)(A) is found to begin on and end on . Such time shall be in
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a d d itio n to other excludable time under the Speedy Trial Act and shall commence as of th e day following the day that would otherwise be the last day for commencement of trial. 4. T h a t any and all subpoenas previously issued shall remain in full force and
e f f e c t through the new trial date. 5. That all motions pending before this Court are hereby held in abeyance. .
D A TED
________________________________________ H O N O R A B L E RANER C. COLLINS U N IT E D STATES DISTRICT COURT JUDGE
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