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

1 JON M. SANDS Federal Public Defender 2 850 W. Adams Street, Ste. 201 Phoenix, Arizona 85007 3 Telephone: (602) 382-2727 4 MILAGROS A. CISNEROS State Bar # 020410 5 [email protected] Asst. Federal Public Defender 6 Attorney for Defendant 7 8 9 10 11 12 13 14 15 vs. Bella Ben-Henry, Defendant. United States of America, Plaintiff, No. CR 04-1018-PHX-JAT MOTION TO CONTINUE SENTENCING (First Request) (Unopposed) IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA

Bella Ben-Henry, through undersigned counsel, respectfully requests that

16 this Court continue her sentencing hearing for 45 days from the current date of May 17 3, 2006. The reason for this continuance is to allow defense counsel additional time 18 to prepare for sentencing. Undersigned counsel was only recently able to review the 19 draft presentence report with Ms. Ben-Henry because she has a limited income and, 20 only recently, was able to come to Phoenix to discuss the plea agreement with 21 undersigned counsel. Ms. Ben-Henry also has very limited access to telephone 22 services, which made it necessary for undersigned counsel to request her presence in 23 person. 24 Undersigned counsel has contacted Assistant U.S. Attorney, Daniel 25 Drake, concerning this motion and Mr. Drake has no objection to the relief requested 26 herein. Undersigned counsel has contacted U.S. Probation Officer Carlos Valentín 27 regarding this motion and he, too, has no objection to the relief requested herein. 28 . . .

Case 2:04-cr-01018-JAT

Document 121

Filed 04/26/2006

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Excludable delay under Title 18 U.S.C. § 3161(h)(8)(A) and (h)(1)(F) Respectfully submitted: April 26, 2006. JON M. SANDS Federal Public Defender s/Milagros A. Cisneros MILAGROS A. CISNEROS Asst. Federal Public Defender

2 may result from this motion or from an order based thereon.

I hereby certify that on April 26, 2006, I electronically transmitted the attached 9 document to the Clerk's Office using the CM/ECF System for filing and transmittal to the following CM/ECF registrants: 10 DAN DRAKE 11 Assistant United States Attorney Two Renaissance Square 12 40 North Central Avenue Suite 1200 13 Phoenix, Arizona 85004-4408 14 TIMOTHY C. HOLTZEN 245 W. Roosevelt Street 15 Phoenix, Arizona 85003 Attorney for Co-Defendant Frederick Marianito 16 JOANNE F. LANDFAIR 17 331 N. First Avenue, Ste. 103 Phoenix, Arizona 85003 18 Attorney for Co-Defendant Ed Preston 19 Copy mailed to: 20 CARLOS VALENTÍN U.S. Probation 21 401 W. Washington Phoenix, Arizona 85003 22 BELLA BEN-HENRY 23 Defendant 24 26 27 28 s/Milagros A. Cisneros 25 M. Cisneros

Case 2:04-cr-01018-JAT

Document 121

Filed 04/26/2006

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