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 00866--PHX- JAT 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 dispostion date presently scheduled for April 30, 2007 for a period of thirty (30) days subject to the Court's calendar and for the foregoing reasons. Counsel requires and request additional time to prepare for disposition. Counsel is unable to locate Ms. Geyer. The only information counsel was able to obtained with regards to her whereabouts is that she was in transit to the District of Arizona. Further, additional time is needed to speak with her regarding the status of her case.

Case 2:04-cr-00866-ROS

Document 88

Filed 04/27/2007

Page 1 of 4

Undersigned counsel avows that he has contacted the Assistant United States Attorney assigned to this matter, Paul Rood regarding his position to this motion and Mr. Rood does not have any objection the relief being requested herein 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 dispostion date for a period of thirty (30) days from April 30, 2007, subject to the Court's calendar. RESPECTFULLY SUBMITTED this 26th day of April, 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 26th day of April, 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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