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

1 ANNE M. WILLIAMS, P.C. 2 ANNE M. WILLIAMS # 012414 3 1837 S. Mesa Drive 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 20
Charles Tyrone Harris, through undersigned counsel, moves this Court to CHARLES TYRONE HARRIS, (Second Request) Defendant. v. United States of America, 2:04-cr-01058-002-PHX-FJM Plaintiff, MOTION TO CONTINUE SENTENCING IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA Suite C-100 Mesa, Arizona 85210-6219 (T) 480-926-0902 (F) 480-892-7099 [email protected] Law Office of Anne M. Williams

7 Attorney for Charles Tyrone Harris

21 continue the sentencing date of June 29, 2007, for an additional thirty (30) days. Mr. 22 Harris requests the additional time for two reasons: First, the date of June 29, 2007 at 23 2:30 conflicts with a previous matter scheduled on counsel's calendar. June 29, 2007, 24 from 1:30 - 4:00 p.m. counsel is in the second day of a 2-day contested dependency 25 26 27 28
hearing before Commissioner Owens in the Mesa Superior Court - Juvenile Division. Second, counsel filed a request for this Court to Order the disclosure of co-defendant, Michael Gamble's criminal history so that Mr. Harris may have this information to

Case 2:04-cr-01058-FJM

Document 156

Filed 06/03/2007

Page 1 of 2

1 compare the sentence given to Mr. Gamble for similar conduct and potentially similar 2 criminal history. As of the filing of this motion, that issue has not been resolved. 3 4 5 6 8 9 10 11 12 13 14 Copy of the foregoing served this date via transmittal 15 of Notice of Electronic Filing to ECF registrant(s): 16 Mr. Kurt Altman
[email protected] /S/ ANNE M. WILLIAMS ANNE M. WILLIAMS, P.C. Submitted via ECF: June 3, 2007. Gamble's documents and prepare for Mr. Harris' sentencing. Assistant U.S. Attorney, Kurt Altman, has been contacted regarding this motion.

Assuming this Court were to grant that request, time will be needed to review Mr.

7 He does not object to the requested continuance.

17 Assistant U.S. Attorney 18 Ms. Anne M. Williams 19 [email protected] Counsel for Mr. Harris 20
Courtesy copy with proposed order provided via Honorable Frederick J. Martone

21 e-mail attachment to: 22 [email protected] 23 24 25 26 27 28 2

Case 2:04-cr-01058-FJM

Document 156

Filed 06/03/2007

Page 2 of 2