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

TYRONE MITCHELL P.C. Tyrone Mitchell, Esq., No. 016267 1700 North Seventh Street, Suite 3 Phoenix, Arizona 85006 Telephone: (602) 258-5749 Facsimile: (602) 258-5233 Attorneys for Defendant IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA UNITED STATES OF AMERICA., Plaintiff, vs. RENEE EILEEN GEYER, Defendant. _____________________________________ ) ) ) ) ) ) ) ) ) ) No. CR 04-866--PHX- ROS MOTION TO DISPOSITION (First Request) CONTINUE

DEFENDANT RENEE EILEEN GEYER, by and through undersigned counsel, respectfully moves this Honorable Court for an Order continuing the re-dispostion date presently scheduled for May 14, 2007 at 11:00 a.m. for a period of fourteen (14) days subject to the Court's calendar and for the foregoing reasons. Defense counsel is currently involved in a two-week murder trial in Arizona Superior Court. Defense counsel is available daily in the early morning before 9:30 a.m or on Fridays. Undersigned counsel attempted to contact the Assistant United States Attorney assigned to this matter, Paul Rood regarding his position to this motion. However, Mr. Rood is unavailable until after the 14 th . Case 2:04-cr-00866-ROS Document 93 Filed 05/05/2007 Page 1 of 3

This Motion is made in good faith and will serve the public's interest in that providing Defendant with effective representation is necessary to insure fairness and protect the Defendant's constitutional rights. A continuance will insure counsel for both the government and the Defendant the reasonable time necessary for effective preparation THEREFORE, based on the foregoing, DEFENDANT RENEE EILEEN GEYER by and through undersigned counsel, respectfully requests that this Honorable Court enter an Order continuing the disposition date for a period of fourteen (14) days from May 14, 2007, subject to the Court's calendar. RESPECTFULLY SUBMITTED this 5th day of May, 2007. TYRONE MITCHELL, P.C.

By

/s/ Tyrone Mitchell Tyrone Mitchell Attorneys for Defendant

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CERTIFICATE OF SERVICE I certify that on the 5th day of May, 2007, I electronically transmitted this 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. Paul Rood, Esq. Assistant U.S. Attorney Two Renaissance Square 40 North Central Avenue Suite 1200 Phoenix, Arizona 85004-4408

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