UNITED STATES DISTRICT COURT
__________________DISTRICT OF TEXAS
_________________ DIVISION

UNITED STATES OF AMERICA 	§
§
v.	§	NO. [CASE NUMBER]
§
[CLIENT]	§
§
                               	§

 	MOTION FOR CONTINUANCE
AND BRIEF - DETENTION HEARING AND PRELIMINARY EXAMINATION

	The defendant, by counsel, makes this first Motion for Continuance and would show the Court the following:
I.
	The defendant is charged by criminal compliant with a violation of ---- U.S.C. § -----, to wit: [OFFENSE].  The case is scheduled for a Detention Hearing and Preliminary Examination on [HEARING DATE] at [HEARING TIME PM/AM].  
II.
	This Motion is not made for delay.  Defendant requests a continuance in order to exercise the right to effective assistance of counsel as guaranteed by the 6th Amendment to the United States Constitution.

III.
	A Motion for Continuance is addressed to the sound discretion of the court and will be disturbed on appeal only upon a showing that there has been abuse of discretion.  The circumstances present in this case reflect a continuance should be granted.
	WHEREFORE, for the reasons set forth above, the defendant respectfully requests the Court to continue this case and reset the Detention Hearing and Preliminary Examination for a date after [HEARING DATE].

						Respectfully submitted,

						BY: __________________________
						Name
						State Bar No. [BAR NUMBER]
						Address
						City, State, Zip
						Telephone 
					    	Attorney for Defendant

CERTIFICATE OF SERVICE

	I certify that on the         day of [MONTH], [YEAR], a copy of the foregoing was hand-delivered to the United States Attorney's Office at 

						Attorney for Defendant

UNITED STATES DISTRICT COURT
________________ DISTRICT OF TEXAS
__________________  DIVISION

UNITED STATES OF AMERICA 	§
§
v.	§	NO. [CASE NUMBER]
§
[CLIENT]	§

O R D E R

	Upon motion of the defendant for a continuance of the Detention Hearing and Preliminary Examination in this case, and the Court having reviewed the facts and legal issues surrounding said motion, this Court hereby GRANTS/DENIES said motion.  The Court orders this case to be reset to the            day of                    , [YEAR], at _________ a.m./p.m. for a Detention Hearing and Preliminary Examination.
	SIGNED this       day of                   , [YEAR].

						                                                                      
						UNITED STATES MAGISTRATE JUDGE