Free Motion to Continue Dispositional Hearing - 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 IN THE UNITED STATES DISTRICT COURT 7 8 9 10 11 vs. 12 MARIO ALBERTO AMADOR, JR., 13 14 15 COMES NOW the defendant, by and through the undersigned attorney, and hereby moves Defendant. United States of America, Plaintiff, MOTION TO CONTINUE DISPOSITION HEARING DISTRICT OF ARIZONA
Case No.: CR04-404-PHX-JAT

16 this Court to continue, for approximately 30 days the disposition hearing in this case, all for the 17 18 19 The government, through A.U.S.A., Glenn McCormick, has been contacted, and has no reasons set forth in the accompanying memorandum of points and authorities.

20 objection to the relief sought herein. 21 22 23 24 25 26 27 28 Case 2:04-cr-00404-JAT Document 93 Filed 10/25/2007 Page 1 of 2 . . . s/ Michael J. Bresnehan Michael J. Bresnehan Attorney for Defendant RESPECTFULLY SUBMITTED this 25th day of October, 2007 by MICHAEL J. BRESNEHAN, P.C.

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MEMORANDUM OF POINTS AND AUTHORITIES The disposition in this case will be contested, and it may involve non-party witnesses. The undersigned attorney will need additional time to prepare his disposition memorandum and in-court presentation, and, thus, requests, on behalf of his client, a continuance

5 6 7 of approximately 30 days of the disposition currently scheduled for October 31, 2007 at 9:00 A.M. The government, through A.U.S.A., Glenn McCormick, has been contacted, and has no

8 objection to the relief sought herein. 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 s/ Michael J. Bresnehan 26 27 28 Case 2:04-cr-00404-JAT Document 93 Filed 10/25/2007 2 Page 2 of 2 Mario Alberto Amador, Jr Defendant Terri Torres US Probation s/ Michael J. Bresnehan Michael J. Bresnehan Attorney for Defendant CERTIFICATE OF SERVICE I hereby certify that on October 25, 2007, I electronically transmitted the attached document to the Clerk's Office using the ECF System for filing and transmittal of a Notice of Electronic Filing to the following ECF registrants: Hon. James A. Teilborg United States District Judge Glenn McCormick, Esq. Asst. U.S. Attorney I hereby certify that on October 25, 2007, I served the attached document by MAIL or FAX on the following, who are not registered participants of the ECF System: MICHAEL J. BRESNEHAN, P.C. RESPECTFULLY SUBMITTED this 25th day of October, 2007 by