Free Motion to Continue - District Court of Arizona - Arizona

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Gabriel Valdez, Jr.
Attorney At Law 337 N. Fourth Avenue Phoenix, Arizona 85003 (602) 254-2010 State Bar No. 014079

Attorney for Defendant IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA UNITED STATES OF AMERICA, Plaintiff, v. NGHIA NGUYEN, Defendant. ) ) ) ) ) ) ) ) ) ) CASE NO. CR-04-559-PHX-EHC MOTION TO CONTINUE SENTENCE HEARING (FIRST REQUEST) (Sentencing set for 12-19-05 at 4:00 p.m. before the Honorable Earl H. Carroll)

Defendant, Nghia Nguyen, by and through undersigned counsel, respectfully requests that this Court continue the Sentencing Hearing currently set for December 19, 2005 at 4:00 p.m. before this Court. The reason for this request is that Counsel needs additional time to investigate sentencing issues. Defense counsel spoke with Assistant U.S. Attorney, Daniel Drake and he has no objection to the continuance. This is the first extension requested to this court. This motion is made in good faith and not for purpose of delay. Excludable delay under 18 U.S.C. section 3161(h) may occur as a result of this motion or of an order based thereon. RESPECTFULLY SUBMITTED this 07 day of December, 2005.

/s/ Gabriel Valdez Jr. Gabriel Valdez Jr. Counsel for Defendant I hereby certify that on December 07, 2005. 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 to the following CM/ECF registrants: Daniel Drake Assistant U.S. Attorney's Office

Case 2:04-cr-00559-EHC

Document 36

Filed 12/07/2005

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