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

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PAUL K. CHARLTON United States Attorney District of Arizona Daniel R. Drake Assistant U.S. Attorney Arizona State Bar No. 003781 Two Renaissance Square 40 N. Central Avenue, Suite 1200 Phoenix, Arizona 85004-4408 Telephone: (602) 514-7500 [email protected]

UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA United States of America CR-04-0952-PHX-SMM Plaintiff, v. Tatia Marie Valenzuela, Defendant. The United States moves the Court to enter an order continuing the sentencing of Tatia FOURTH MOTION TO CONTINUE SENTENCING

15 Marie Valenzuela for four to six weeks in order to permit additional information to be gathered 16 concerning restitution. The indictment alone references seven bank or credit union accounts, and 17 each account had between 10 and 20 checks written to different merchants. There were 18 additional accounts included in the scheme but not the indictment. Efforts to contact potential 19 victims and gather information about losses have met with mixed results. The additional time 20 is requested so the information can be assembled, shared with opposing counsel, and presented 21 to the court in a manageable fashion. Counsel undersigned has communicated with Roger Margolis, attorney for Ms. 22 23 Valenzuela, regarding the potential postponement of the sentencing. There is no objection to 24 this requested continuance. 25 Excludable delay under 18 U.S.C. § 3161(h) may occur as a result of this motion or an 26 order based thereon. 27 /// 28 ///

Case 2:04-cr-00952-SMM

Document 124

Filed 12/12/2006

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Respectfully submitted this 12th day of December, 2006. PAUL K. CHARLTON United States Attorney District of Arizona s/Daniel R. Drake

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Roger Marolis Attorney at Law I served the attached document by fax on the following person who is not a registered participant of the ECF system: John Evanko United States Probation Officer I hereby certify that on December 12, 2006, 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

DANIEL R. DRAKE Assistant U.S. Attorney

Case 2:04-cr-00952-SMM

Document 124

Filed 12/12/2006

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