Free Motion to Continue - District Court of Arizona - Arizona

1 JON M. SANDS Federal Public Defender 2 District of Arizona 3 850 W. Adams, Suite 201 Phoenix, Arizona 85007 4 Telephone: (602) 382-2721 5 JEANETTE E. ALVARADO, #016111 Asst. Federal Public Defender 6 Attorney for Defendant 7 IN THE UNITED STATES DISTRICT COURT 8 DISTRICT OF ARIZONA 9 10 11 12 13 14 15 16 17 Patrick S. Hurley respectfully moves this Court for an order continuing 18 the sentencing in the above matter from August 8, 2005 for a period of at least three 19 (3) weeks. The basis for this requested continuance is undersigned counsel needs 20 additional information to present to the Court at sentencing and an additional three 21 (3) weeks are requested to gather the information to present to the Court. 22 Stephen W. Laramore, Assistant U.S. Attorney, has been contacted and 23 24 25 26 has no objection to this continuance. Guillermo Pena, U.S. Probation Officer, is out of the office until August 15, 2005. A message has been left for him, but no response was received regarding his position on the requested continuance. vs. (Second Request) Patrick S. Hurley, Defendant. United States of America, Plaintiff, No. CR-04-0975-PHX-SRB MOTION TO CONTINUE SENTENCING

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Case 2:04-cr-00975-SRB

Document 32

Filed 08/02/2005

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It is expected that excludable delay under Title 18 U.S.C. §

2 3161(h)(1)(I) may occur as a result of this motion or from an order based 3 thereon. 4 5 6 7 8 9 10 Copy of the foregoing was electronically mailed 11 by using the CM/ECF system nd 12 on this 2 day of August, 2005, to: 13 STEPHEN W. LARAMORE Assistant United States Attorney 14 Two Renaissance Square 40 North Central Avenue 15 Suite 1200 16 Phoenix, Arizona 85004-4408 17 18 Copy mailed to: s/____________________________ JEANETTE E. ALVARADO Asst. Federal Public Defender Respectfully submitted: August 2, 2005. JON M. SANDS Federal Public Defender

GUILLERMO PENA 19 United States Probation Sandra Day O'Connor U.S. Courthouse 20 401 W. Washington Street 21 Suite 410 Phoenix, Arizona 85003 22 23 PATRICK S. HURLEY Defendant 24 25 s/ Alvarado J. 26 \ContSentMTN 27 28
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Case 2:04-cr-00975-SRB

Document 32

Filed 08/02/2005

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