Free Motion to Continue - District Court of Arizona - Arizona

1 2 3 4 5 6 7

ALAN M. SIMPSON, P.C. Attorneys at Law Meridian Bank Tower 3550 North Central Avenue, Suite 1006 Phoenix, Arizona 85012 (602) 222-4878 Fax (602) 222-4879
State Bar No. 006203 e-mail: [email protected]

Attorneys for Karen Sue Blair, defendant. IN THE UNITED STATES DISTRICT COURT

8 DISTRICT OF ARIZONA 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 v. KAREN SUE BLAIR, Defendant. UNITED STATES OF AMERICA, Plaintiff, MOTION TO ENLARGE RULE 32(f)(1) PERIOD AND CONTINUE SENTENCING No. CR 04-1027-PHX-RGS

Karen Sue Blair moves the Court for an order continuing the sentencing hearing scheduled for August 30, 2005 and to enlarge the period for the filing of her objections to the draft presentence investigation report. (PSR). 1. The draft PSR was submitted to undersigned's office by fax on Friday, August 5, 2005. That date is less than that identified in Rule 32 (e)(2); however, the defense did advise the presentence writer that it believed that an adequate period was being provided given the character of this case. Nonetheless, upon review of the draft report the defense believes there is an error on the loss calculation, which shall require an objection. 2. The record in this case reflects that the parties worked diligently to establish an accurate loss calculation. (See, Motions to Continue addressing efforts being taken to reach

Case 2:04-cr-01027-RGS

Document 18

Filed 08/15/2005

Page 1 of 2

1 2 3 4 5 6 7 8

agreement). A brief enlargement of ten-days is requested to the period established by Rule 32(f)(1) to provide a written response to the loss calculation in the draft report. 3. The period sought to enlarge the objection date shall require an adjournment of the sentencing hearing. The defense has conferred with Assistant United States Attorney Michelle Hamilton-Burns who advised that the government does not oppose this request.

Respectfully submitted this 15th day of August 2005.
9 10
3550 North Central Ave, Suite 1006 Phoenix, Arizona 85012 (602) 222-4878

11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27

ALAN M. SIMPSON, P.C.

/s/ _______________________ ALAN M. SIMPSON Counsel for Ms. Karen Sue Blair Copies of the foregoing mailed/delivered this ___ day of August, 2005, to: Clerk of U.S. District Court (Original plus 1 copy) (hand-delivered) / Electronic Filing Michelle Hamilton-Burns Assistant United States Attorney Two Renaissance Building 40 N. Central Avenue, Suite 1200 Phoenix, Arizona 85004

2 Case 2:04-cr-01027-RGS Document 18 Filed 08/15/2005 Page 2 of 2