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

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ANNE M. WILLIAMS, P.C. Law Office of Anne M. Williams ANNE M. WILLIAMS # 012414 [email protected] Attorney at Law 1837 S. Mesa Drive Suite C-100 Mesa, Arizona 85210-6219 (T) 480.926-0902 (F) 480.892-7099 Attorney for Charles Tyrone Harris

IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA

United States of America, 2:04-cr-01058-002-PHX-FJM Plaintiff, MOTION TO SENTENCING v.

CHARLES TYRONE HARRIS, Defendant.

(Second Request)

Charles Tyrone Harris, through undersigned counsel, moves this Court to continue the sentencing date of May 31, 2007, for an additional thirty (30) days. Mr. Harris requests the additional time in order to have Mr. Brian Russo, attorney for Mr. Gamble, respond to our request for his client's Presentence Investigation Report regarding prior criminal history. Mr. Russo was contacted approximately 3 weeks ago. He indicated the need to contact his client for permission regarding our request. As of this date, counsel has not heard back from Mr. Russo.

Case 2:04-cr-01058-FJM

Document 151

Filed 05/21/2007

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Assistant U.S. Attorney, Kurt Altman, has been contacted regarding this motion. He does not object to the requested continuance.

Respectfully submitted: May 21, 2007.

/S/ ANNE M. WILLIAMS ANNE M. WILLIAMS, P.C.

Copy of the foregoing served this date via transmittal of Notice of Electronic Filing to CM/ECF registrant(s): Mr. Kurt Altman [email protected] Assistant U.S. Attorney Ms. Anne M. Williams [email protected] Counsel for Mr. Harris Mr. Brian Russo [email protected] Counsel for Mr. Gamble Courtesy copy with proposed order provided via e-mail attachment to: Honorable Frederick J. Martone [email protected]

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Case 2:04-cr-01058-FJM

Document 151

Filed 05/21/2007

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