Free Motion to Continue - District Court of Arizona - Arizona

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LAW OFFICES OF SIPE & LANE, PLC 637 South 48th Street, Suite 201 Tempe, AZ 85281 480-776-5757- Telephone 480-776-5758- Facsimiile JAMES HANKEY #016526 Attorney for Defendant IN THE UNITED STATES DISTRICT COURT,

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DISTRICT OF ARIZONA, PHOENIX
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UNITED STATES OF AMERICA,
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Case No.: CR00-44-1-PHX-ROS MOTION TO CONTINUE

Plaintiff,
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vs.
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HOA THI TUYET LE,
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Defendant

The Defendant, HOA LE, by and through undersigned counsel, respectfully requests that this Court continue the admit/deny hearing now set for August 8, 2005. Counsel is still gathering mitigation information to present to the Court, and still is investigating the facts surrounding the alleged probation violation. One important mitigation witness, Arden Dorn, is on vacation in Colorado until August 22. He is pastor of the church that was the victim in the case for which Ms. Le was placed on probation. He is an extremely strong supporter of Ms. Le, but in addition to being able to provide character information concerning Ms. Le, Counsel believes that Pastor Dorn will be able to corroborate some important factual mitigation information that the defense wishes to present to the Court.

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Additionally, Counsel has requested that the Maricopa County Attorney s Office arrange interviews with the arresting officers in this case, and the defense would prefer not to admit or deny the allegations until the officers have been interviewed. Counsel has discussed this proposed continuance with United States Probation Officer Randy Muncey, and with Assistant United States Attorney Darcy Cerow, and both individuals

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have authorized Counsel to inform this Court on their behalf that they do not oppose the motion.
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This motion is made in good faith and not for the purpose of delay. Ms. Le agrees to waive any jurisdictional time limit necessary for the granting of this motion.

JAMES HANKEY Attorney for Defendant

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COPY OF THE FOREGOING mailed/delivered this 4th day of August 2005 to,

The Honorable Roslyn O. Silver Sandra Day O Connor U.S. Courthouse 401 W. Washington St. Suite 130, SPC 1 Phoenix, AZ 85003-2118 Assistant United States Attorney Darcy Cerow Two Renaissance Square 40 N. Central Avenue, Suite 1200 Phoenix, AZ 85004-4408 United States Probation Officer Randy Muncey 230 N. 1st Ave., Suite 406 Phoenix, AZ 85003

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This document was created with Win2PDF available at http://www.daneprairie.com. The unregistered version of Win2PDF is for evaluation or non-commercial use only.

Case 2:00-cr-00441-ROS

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