Free Motion to Continue Dispositional Hearing - District Court of Arizona - Arizona

1 2 3 4 5 6 7 8 9 10

Joanne F. Landfair, Esq. 331 North First Avenue Suite 150 Phoenix, AZ 85003-4528 Phone & fax: (602) 452-2945 [email protected] Arizona State Bar # 009173 Attorney for Defendant

UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA

UNITED STATES OF AMERICA,
11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27

) ) Plaintiff, ) vs. ) ) Keith Rea Hunking, ) ) Defendant. ) __________________________________)

No.CR-04-994-01-PHX-PGR MOTION TO CONTINUE (FIRST REQUEST)

COMES NOW the defendant Keith Rea Hunking, by and through through counsel undersigned, and hereby respectfully moves the Court to continue the disposition hearing currently set for January 18, 2005, at 9:30 a.m., for 30 days to allow additional time for Dr. Potts to prepare his report. Mr. Hunking is scheduled to see Dr. Potts this week, and Dr. Potts has indicated that he will be able to have his report prepared about two weeks after the evaluation. The AUSA in the matter, Darcy Cerow, has no objection to this request for continuance. Excludable delay under 18 U.S.C. § 3161 (h)_____ will occur as a

1 Case 2:04-cr-00994-PGR Document 48 Filed 01/16/2006 Page 1 of 2

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26

result of this motion or of an order based thereon.
.

RESPECTFULLY SUBMITTED this 16th day of January, 2006.

/s/Joanne F. Landfair Joanne F. Landfair Attorney for Defendant

CERTIFICATE OF SERVICE I hereby certify that on January 16th, I electronically transmitted the attached document to the Clerk's Office using the CM/ECF System for filing and transmittal of a Notice of Electronic Filing to the following CM/ECF registrants: AUSA Darcy Cerow /S/ Joanne F. Landfair

Hunking-MTC

2 Case 2:04-cr-00994-PGR Document 48 Filed 01/16/2006 Page 2 of 2