Free Motion to Continue Sentencing - District Court of Arizona - Arizona

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Jason R. Leonard, 018067 Leonard Law Offices, P.C. 1 Renaissance Square, 2 N. Central Ave. Suite 735, Phoenix, AZ 85004 Telephone: 602-443-2220 Facsimile: 602-443-2221 e-mail:[email protected] Attorney for Defendant

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA

UNITED STATES OF AMERICA, Plaintiff, vs. FOSTER KENNETH, Defendant.

No. CR 04-0373-PHX-JAT MOTION TO CONTINUE

( 9th Request)

Defendant, through undersigned counsel moves to continue the Firm Trial Currently set for 04/17/2006 for no less than 14 days. For the Following Reason(s) Counsel for the defendant is currently in case transfer in State Superior Court and had anticipated being in trial, in fact, counsel is next in line. As a result Counsel has not had the opportunity and will not have such opportunity to meet with the defendant prior to the scheduled time for sentencing. In addition, Counsel apologizes in advance for the lack of timeliness of this filing, however, due to personnel, health issues Counsel was unaware that this motion had not been filed. Counsel for the Defendant contacted AUSA Dick Mesh, who stated he no objections to this final continuance request.

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Excludable delay under 18 U.S.C. §3161(h) (1)(F) and 8(A) will occur as a result of this motion or an order based thereon.

RESPECTFULLY SUBMITTED this fourteenth day of April, 2006.

By:

s/Jason R. Leonard

Jason R. Leonard, 018067 Leonard Law Offices, P.C. 1 Renaissance Square, 2 N. Central Ave. Suite 735, Phoenix, AZ 85004 Telephone: 602-443-2220 Facsimile: 602-443-2221 e-mail:[email protected] Attorney for Defendant

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MAIL CERTIFICATE I HEREBY CERTIFY THAT ON FOURTEENTH DAY OF APRIL, 2006, I ELECTRONICALLY TRANSMITTED THE ATTACHED DOCUMENT TO THE CLERK'S OFFICE USING THE CM/ECF SYSTEM FOR FILING AND TRANSMITTAL OF A NOTICE OF ELECTRONIC FILING TO THE FOLLOWING CM/ECF REGISTRANTS:

UNITED STATES DISTRICT COURT SANDRA DAY O'CONNOR COURTHOUSE 401 WEST WASHINGTON STREET PHOENIX, ARIZONA 85003 HONORABLE JAMES A. TEILBORG UNITED STATES DISTRICT COURT SANDRA DAY O'CONNOR U.S. COURTHOUSE, SUITE 523 401 WEST WASHINGTON STREET, SPC 51 PHOENIX, AZ 85003-2154 RICHARD MESH TWO RENAISSANCE SQUARE 40 N. CENTRAL AVE PHOENIX, AZ 85004-4408

BY: JASON R. LEONARD

:

s/Jason R. Leonard

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