IN THE DISTRICT COURT OF THE UNITED STATES

FOR THE MIDDLE DISTRICT OF ALABAMA

EASTERN DIVISION

)

In the Matter of the Extradition of )

MARIA DEL ROSARIO MORENO VAZQUEZ,) CV. NO. 3:06cv761-MEF-CSC

a/k/a MARIA COONLEY )

 )

UNITED STATES’S MOTION FOR STATUS CONFERENCE

AND FOR SETTING OF EXTRADITION HEARING

Comes now the United States of America, by and through Leura G. Canary, United

States Attorney for the Middle District of Alabama, and hereby requests a status

conference in this case and for the Court to set an extradition hearing in this matter.

1. On December 21, 2005, an arrest warrant was obtained and later executed

against Maria del Rosario Moreno-Vazquez in this case. Moreno-Vazquez was released

on electronic monitoring pending the receipt of a formal extradition request from the

country of Mexico. 

2. On August 23, 2006, the United States filed the formal extradition

paperwork from Mexico and requested an extradition hearing in this matter. 

Additionally, at that time the United States filed an extradition memorandum with the

factual basis for extradition as well as the applicable law supporting extradition. During

this time, however, the United States learned that Mexico had a second request for

extradition pending at the State Department, and, the United States therefore favored

postponing the extradition hearing until the second request was completed. 

3. On September 25, 2006, the United States filed Mexico’s second arrest

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warrant and second ground for extradition. On October 11, 2006, the Court held a status

conference. At that time, the parties asked the Court for additional time so that the parties

could prepare for the extradition hearing. 

3. On February 22, 2008, this case was reassigned to Assistant U.S. Attorney

Christopher A. Snyder to handle while Assistant United States Attorney Todd Brown is

on miliary leave. From February 22, 2008 until March 24, 2008, AUSA Snyder

attempted to contact defense counsel about the status of this matter. On March 24, 2008,

AUSA Snyder was able to reach defense counsel, who indicated that he had attempted to

return the United States’s calls, but that he had problems with the United States’s phone

system. 

4. During this conversation, defense counsel indicated that he was missing

several pages from his extradition paperwork. The parties have been working since this

point to obtain the pages that are missing. Currently, the United States is awaiting a list

of pages that defense counsel says are missing. 

5. In light of the fact this case has been pending almost two and one-half

years, the United States submits that both parties have had more than sufficient time to

prepare their cases for an extradition hearing. In order to move expeditiously, the United

States requests that the Court set a conference (1) so that both parties can address any

additional issues they may have, and (2) so the Court can set a date for an extradition

hearing – hopefully no more than 60 days from the date of this status conference. 

6. The United States has spoke with defense counsel, and both parties are

available at any time on April 1 or 4, 2008 and prior to 3:00 p.m. on April 3, 2008, for a

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status conference. 

Respectfully submitted this the 31th of March, 2008.

LEURA G. CANARY

UNITED STATES ATTORNEY

/s/ Christopher Snyder

CHRISTOPHER A. SNYDER

Assistant United States Attorney

131 Clayton Street

Montgomery, AL 36104

Phone: (334)223-7280

Fax: (334)223-7135

E-mail: christopher.a.snyder@usdoj.gov

Certificate of Service

I hereby certify that on March 31, 2008, I electronically filed the foregoing with

the Clerk of the Court using the CM/ECF system, which will send notification of such

filing to the following: Ben Elton Bruner. 

/s/ Christopher Snyder

CHRISTOPHER A. SNYDER

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