Free Motion to Extend Time - District Court of Arizona - Arizona

1 LAW OFFICES OF MICHAEL J. BRESNEHAN, P.C. Michael J. Bresnehan, Esquire 2 1761 East McNair Drive, Suite 101 Tempe, AZ 85283-5002 3 480-345-7032 [email protected] 4 State Bar No.: 009415 5 Attorney for Defendant 6 7 8 9 10 11 vs. 12 KINDY JONAGAN, 13 14 15 COMES NOW the defendant, by and through the undersigned attorney, and hereby moves Defendant. United States of America, Plaintiff, IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA Case No.: CR-04-00820-006-PHX-FJM MOTION TO EXTEND DEADLINE FOR FILING OBJECTIONS TO PSI REPORT AND SENTENCING MEMORANDUM

16 this Court to extend the deadline for filing defendant's objections to the presentence report and 17 18 19 20 accompanying memorandum of points and authorities. The government, through Assistant U.S. Attorney, Gary Restaino, has been contacted, and defendant's sentencing memorandum to May 8, 2006, all for the reasons set forth in the

21 has no objection to the relief sought herein. 22 23 24 25 26 27 28 Case 2:04-cr-00820-FJM Document 245 Filed 05/05/2006 Page 1 of 2 s/ Michael J. Bresnehan Attorney for Defendant RESPECTFULLY SUBMITTED this 5th day of May, 2006 by MICHAEL J. BRESNEHAN, P.C.

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MEMORANDUM OF POINTS AND AUTHORITIES This is an extremely complex commercial fraud case involving hundreds of thousands of business and other documents. Sifting through this mountain of evidence in order to prepare objections to the presentence report and defendant's sentencing memorandum has been time consuming. For this reason, the defendant, through counsel, is requesting that the deadline for filing her

8 objections to the presentence report and her sentencing memorandum be continued one (1) business 9 day from May 5, 2006 to May 8, 2006. 10 11 12 13 14 15 RESPECTFULLY SUBMITTED this 5th day of May, 2006 by MICHAEL J. BRESNEHAN, P.C. s/ Michael J. Bresnehan Attorney for Defendant CERTIFICATE OF SERVICE

16 X I hereby certify that on May 5, 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 17 to the following CM/ECF registrants: 18 Gary Restaino, Esq. Craig W. Haraga Hon. Frederick J. Martone US Probation Office United States District Judge 19 Assistant U.S. Attorney 20 X I hereby certify that on May 5, 2006, I served the attached document by Mail on the following, 21 who are not registered participants of the CM/ECF System: 22 Kindy Jonagan Defendant 23 24 25 26 27 28 Case 2:04-cr-00820-FJM Document 245 2Filed 05/05/2006 Page 2 of 2 s/ Michael J. Bresnehan