Free Motion to Continue - District Court of Arizona - Arizona

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CHARLES M. McNULTY
State Bar No. 06707 337 North Fourth Avenue Phoenix, Arizona 85003-1571 (602) 262-4224

Attorney for Defendant

UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA UNITED STATES OF AMERICA, Plaintiff, vs. ERICK MONTIEL-LOPEZ, Defendant. MOTION TO CONTINUE SENTENCING HEARING No. CR 03-273-02-PHX-PGR

Defendant Erick Montiel-Lopez moves this Court for an order continuing the

19 sentencing hearing presently set for October 31st, 2005 for a period of 30 days to allow counsel 20 additional time to prepare for the hearing and to submit objections to the presentence report. 21 22 23 24 25 26 27 28

Counsel had an angiogram performed on October 10th, and was off work for several days and is just now beginning to work fulltime again. Assistant U.S. Attorney Joseph E. Koehler has no objection to this request. Excludable delay under 18 U.S.C. §3161(h)(1)(F) and (8)(A) will occur as a result of this motion or from an order based thereon. RESPECTFULLY SUBMITTED this 20th day of October, 2005.

s/Charles M. McNulty CHARLES M. McNULTY Attorney for Defendant

Case 2:04-cr-00594-ROS

Document 106

Filed 10/20/2005

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CM/ECF registrant October, 2005, to:

Joseph E. Koehler Assistant U.S. Attorney 15 Two Renaissance Square 16 40 North Central Avenue, Suite 1200 Phoenix, Arizona 85004 17
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s/Charles M. McNulty

Case 2:04-cr-00594-ROS

Document 106

Filed 10/20/2005

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