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

Filing 731

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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 JON M. SANDS Federal Public Defender HUGO C. REYNA Assistant Federal Public Defender State Bar No.022262 407 W. Congress, Suite 501 Tucson, AZ 85701-1355 Telephone: (520)879-7500 Attorney for Defendant hugo_reyna@fd.org IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA ) ) Plaintiff, ) ) vs. ) ) Timothy John Elizarraras, ) ) Defendant. ) __________________________________ ) United States of America, CR 09-1182-TUC-CKJ (JCG) MOTION TO CONTINUE INITIAL APPEARANCE; ARRAIGNMENT; DETENTION HEARING; AND ATTORNEY APPOINTMENT HEARING (First Request) It is expected that excludable delay under Title 18, United States Code, 3161(h)(7), will occur as a result of this motion or an order based thereon. Defendant Timothy Elizarraras, by and through counsel undersigned, hereby requests a sixty-day (60) continuance of the Initial Appearance; Arraignment; Detention Hearing; and Attorney Appointment Hearing that is currently scheduled for November 30, 2009, at 11:30a.m. based upon the following reasons: 1) Defendant resides in Las Vegas, Nevada and needs to travel to Tucson, Arizona to appear before this Court. Defense counsel has been in contact with the U.S. Marshal's Office to arrange transportation to Tucson, Arizona. Counsel has learned that Defendant does not have medical clearance to travel by plane. Additional time is required to secure proper transportation of Defendant that ensures his safe travel due to his medical condition. Assistant U.S. Attorney Carmen Corbin, has been contact and has no objection to said continuance. November 24, 2009. JON M. SANDS Federal Public Defender /s/ Hugo C. Reyna HUGO C. REYNA Assistant Federal Public Defender 2) RESPECTFULLY SUBMITTED: 1 2 ECF Copy to: CARMEN CORBIN, 3 Assistant United States Attorney 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

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