Free Motion to Continue - District Court of Arizona - Arizona

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LAW OFFICE OF NEIL C. LABARGE
NEIL C. LABARGE State Bar No. 13920 11 W . Jefferson St., #2 Phoenix, AZ 85003 (602) 252-4090 FAX (602) 252-2111 Attorney for Defendant Corralejo

IN THE UNITED STATES DISTRICT COURT 7 DISTRICT OF ARIZONA 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Defendant. Comes now defendant, through attorney Neil C. LaBarge, and respectfully requests that the court continue the sentencing currently set for August 29, 2005 for a period of thirty (30) days. This motion is based on the following grounds: 1) Undersigned counsel will be out of state from August 17-27, 2005, and will not be able to review the Pre-Sentence Report with the defendant and file objections thereto before then. AUSA Camille Bibles also advises that she will be out of state on the currently set sentencing date, and would prefer to be present at sentencing. 2) Undersigned counsel has discussed this request with both AUSA Camille Bibles and USPO Mark Nebgen, and neither has any opposition to this request. It is anticipated that excludable delay may occur pursuant to 18 USC 3161(h)(8)(A) as a result of this motion or an order based thereon. v. RICARDO CORRALEJO, U.S.A., Plaintiff, MOTION TO CONTINUE SENTENCING, AND ORDER No. CR04-1090-1-PHX-JAT

Case 2:04-cr-01090-JAT

Document 39

Filed 08/15/2005

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1 2 3 LAW OFFICE OF NEIL C. LABARGE 4 5 ________________________________ 6 NEIL C. LABARGE 7 8 9 Original filed with the following via ECF this date: August 15, 2005. 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -2Filed 08/15/2005 Camille Bibles, AUSA 928-556-0759 Clerk of the Court 401 W. Washington St. Phoenix, AZ 85003 Copies e- mailed to the following on this date: August 15, 2005. Hon. James A. Teilborg [email protected] Copies faxed to the following on this date: August 15, 2005. Respectfully submitted this date: August 15, 2005.

Case 2:04-cr-01090-JAT

Document 39

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1 2 3 4 5 6 7 8 9 10 11 v. 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 ___________________________________ Honorable James A. Teilborg, U.S. District Court, District of Arizona -3Filed 08/15/2005 THE COURT, having reviewed the Motion to Continue Sentencing, and good cause appearing, IT IS ORDERED granting the motion and continuing the Sentencing to the ____ day of _________________, 2005 at ________ o'clock. IT IS FURTHER ORDERED that excludable delay in this case under 18 USC 3161 will commence on __________________ for a total of ______ days. SO ORDERED THIS DATE: __________________________. Defendant. RICARDO CORRALEJO, U.S.A., Plaintiff, No. CR04-1090-1-PHX-JAT ORDER IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA

Case 2:04-cr-01090-JAT

Document 39

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