IN THE UNITED STATES DISTRICT COURT
FOR THE _____________ DISTRICT OF TEXAS
[DIVISION] DIVISION

UNITED STATES OF AMERICA,       	§
				            	§
				            	§
v.				            	§	No. [CASE NO.]  
                                				§
[CLIENT NAME]		              	§

MOTION FOR CONTINUANCE
AND BRIEF - DETENTION HEARING AND ARRAIGNMENT  

	The defendant, by counsel, makes this first Motion for Continuance and would show the Court the following:
I.
	[CLIENT NAME] is charged by Indictment with ___ U.S.C. § ___, [NAME OF CHARGE].  The case is scheduled for a detention hearing and Arraignment on [DATE OF HEARING] at [TIME A.M. / P.M.].   

II.
	This Motion is not made for delay.  Good cause for this continuance exists because the counsel for the Defendant needs more time to develop detention evidence. 
	In addition, Defendant requests such 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.
	The  circumstances present in this case reflect a continuance should be granted.
	WHEREFORE, for the reasons set forth above, Defendant respectfully requests the Court to continue this case and reset the detention hearing and arraignment for a later 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 __________________,20____, a copy of the foregoing was hand-delivered to the United States Attorney's office at ___________________________.

						                                                           								Attorney for Defendant

IN THE UNITED STATES DISTRICT COURT
FOR THE _______________ DISTRICT OF TEXAS
[DIVISION] DIVISION

UNITED STATES OF AMERICA,       	§
				            	§
				            	§
v.				            	§	No. [CASE NO.]  
                                				§
[CLIENT NAME]		              	§

O R D E R

	Upon motion of the defendant, [CLIENT NAME], for a continuance of the detention hearing and arraignment 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                    , 20____, at ____________ _____.m. for a detention hearing and arraignment.
	SIGNED this       day of                                    , 20_____.

						                                                                           
						UNITED STATES MAGISTRATE JUDGE