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

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Robert Bruce Stirlin g, II, Esq. Attorney at Law 33 West Willetta Street Phoenix, Arizona 85003 Tel. (602) 460-5631 Fax (602) 285-1224 State Bar No. 006037 [email protected] Attorney for Defendant IN THE UNITED STATES DISTRICT COURT

7 FOR THE DISTRICT OF ARIZONA 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 The defendant, Miguel Ramirez Urea, through counsel undersigned, hereby moves this Court for its order continuing the sentencing set for Monday, March 13, 2006. This request is made because defense counsel learned this morning, March 10, 2006, that the Mr. Ramirez's wife died this past Monday, March 6, 2006. Counsel just met with Mr. Ramirez on Wednesday, March 8, earlier this week. Mr. Ramirez had not yet learned of his wife's passing. Counsel is not sure if Mr. Ramirez knows of his wife's death, although he may have learned of her passing from relatives since counsel's visit W ednesday. Counsel discussed this issue today with William Solomon, the attorney for the government, who said he does not oppose this request for a continuance. This request is sought to provide Mr. Ramirez with time to grieve. Also, it will permit counsel additional time to assess the impact of her death on the defendant and on other family members. Counsel believes the impact of the defendant's wife's death is relevant to a just and reasonable sentence in this case. v. MIGUEL RAMIREZ-UREA, AKA MIGUEL F. OROPEZA, Defendant. UNITED STATES OF AMERICA, Plaintiff, ) ) ) ) ) ) ) ) ) )

CA SE NO . CR 04-00868-001-PHX-FJM MOTION TO CONTINUE SENTENCING DUE TO DEATH OF DEFENDANT'S W IFE [FIRST MOTION TO CONTINUE SENTENCING]

Case 2:04-cr-00868-FJM

Document 27

Filed 03/10/2006

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Counsel was informed by the defendant's daughter, Noelia, that the defendant's children lived with their mother in Mexico at the time of her death. The defendant's wife and children returned to Mexico following his arrest. The children's futures are now uncertain and counsel awaits the receipt of additional information from Mr. Ramirez's family regarding their circumstances. Counsel does not believe that any order issued as a result of this motion will result in excludable time. Respectfully submitted this 10th day of March, 2006.

/s/ Robert Bruce Stirling, II ________________________________ Robert Bruce Stirling, II, Esq. Attorney for Defendant

Certificate of Service I, Robert Bruce Stirling, II, certify that the 10 th day of March, 2006, I electronically transmitted the foregoing document to the Clerk of the United States District Court, District of Arizona, using the CM/ECF system for filing and transmittal of a Notice of Electronic Filing to the following CM/ECF registrants: WILLIAM SOLOMON Assistant United States Attorney Two Renaissance Square 40 North Central Avenue, Suite 1200 Phoenix, Arizona 85004-4408 Attorney for the Government Copy of the foregoing document mailed this 10 th day of March, 2006, to: Manuel Ramirez-Urea

22 23 24 25 26 27 28 /s/ Robert Bruce Stirling, II By Robert Bruce Stirling, II, Esq.

Case 2:04-cr-00868-FJM

Document 27

Filed 03/10/2006

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