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Case 1:12-cr-00184-RJL Document 157 Filed 02/12/16 Page 1 of 3

UNITED STATES DISTRICT COURT


FOR THE DISTRICT OF COLUMBIA
UNITED STATES
v.
ALFREDO BELTRN LEYVA,
Defendant.

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Criminal No. 12-0184(RJL)


Trial: 2/16/2016

DEFENDANTS MOTION TO CONTINUE TRIAL


DEFENDANT Alfredo Beltrn Leyva (Beltrn Leyva), by and through
undersigned counsel, respectfully submits this Motion to Continue Trial, Mr. Beltrn Leyva
states as follows:
1.

Trial in this matter is scheduled for February 16, 2016. Just yesterday,

Mr. Beltrn Leyva became aware of evidence located outside of the United States that has a
direct bearing on the credibility of several of the governments cooperating witnesses, whom the
government named just this week. In a prosecution that is principally based on cooperator
testimony, such evidence is material and crucial to the defense of the charges.
2.

Mr. Beltrn Leyva recognizes that the Court and the government have

expended great resources to be prepared as as scheduled. Nevertheless, Mr. Beltrn Leyva


cannot proceed to trial without being able to obtain the evidence and use it in his defense.
Counsel has made an ex parte proffer to the Court pertaining to the nature of the evidence.
Considering that the evidence is outside the United States and efforts must be made to obtain it
in time for trial, Mr. Beltrn Leyva respectfully requests a 90-day continuance of trial.

Case 1:12-cr-00184-RJL Document 157 Filed 02/12/16 Page 2 of 3

WHEREFORE, for the foregoing reasons and any other that may become
apparent to the Court, Mr. Beltran Leyva respectfully requests that this Motion be GRANTED.
Dated: Washington, DC
February 12, 2016

Respectfully submitted,
BALAREZO LAW
By:

/s/
____________________________________
A. Eduardo Balarezo
D.C. Bar # 462659
400 Fifth Street, NW
Suite 300
Washington, DC 20001
Tel: (202) 639-0999
Fax: (202) 639-0899
E-mail: aeb@balarezolaw.com
Counsel for Defendant Alfredo Beltrn Leyva

Case 1:12-cr-00184-RJL Document 157 Filed 02/12/16 Page 3 of 3

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 12th day of February 2016, I caused a true and
correct copy of the foregoing Defendants Motion to Continue Trial to be delivered via
Electronic Case Filing to the parties in this case.
/s/
______________________________
A. Eduardo Balarezo

Case 1:12-cr-00184-RJL Document 157-1 Filed 02/12/16 Page 1 of 1

UNITED STATES DISTRICT COURT


FOR THE DISTRICT OF COLUMBIA
UNITED STATES
v.
ALFREDO BELTRN LEYVA,
Defendant.

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Case No. 12-CR-184 (RJL)

ORDER
Upon consideration of Defendants Motion to Continue Trial, any opposition
thereto and for good cause shown, it is this _____ day of _____________ 2016, hereby
ORDERED, that the trial scheduled for February 16, 2016, is hereby
VACATED; and it is further
ORDERED, that the new trial is scheduled for __________________ 2016.

_____________________________________
RICHARD J. LEON
UNITED STATES DISTRICT JUDGE