Free Motion to Continue - District Court of Arizona - Arizona

LAW OFFICES OF THOMAS JACOBS 271 North Stone Avenue Tucson, Arizona 85701 PHN : (520) 628-1622 FAX : (520) 628-4534 Thomas Jacobs, Esq. State Bar No. 013275 P.C.C. No. 64489 Attorney for: JUAN FELIX. UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA UNITED STATES OF AMERICA, Plaintiff, v. JUAN FELIX, Defendant. ) ) ) ) ) ) ) ) ) )

No. CR04-403-02-PHX-ROS

MOTION TO CONTINUE SENTENCING [6th Request]

It is expected that excludable delay under 18 U.S.C. §3161(h)(3)(B)(8)(A) will occur as a result of this motion or from an order based thereon. COMES NOW Defendant, by and through his attorney, and hereby moves this Court for a continuance of the Sentencing Hearing date presently scheduled on August 22, 2005. This request for a continuance is made for the following reason(s): 1. The Government and Defense counsel are exchanging additional Therefore,

information that must be evaluated prior to Sentencing hearing.

undersigned counsel respectfully requests that this matter be continued for at least thirty (30) days.

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2.

Undersigned counsel's office has spoken with Assistant U.S. Attorney

Glenn McCormick, who stated he has no objection to the continuance. Undersigned counsel's staff has also spoken with Justine Kozak, U.S. Probation Officer, who stated she has no objection to the continuance. 3. Pursuant to Local Rule 1.10(n), Defendant hereby advises the court that this

is the sixth requested extension. WHEREFORE, undersigned counsel requests that the sentencing hearing date of this matter be continued to next convenient court date. RESPECTFULLY SUBMITTED this 17TH day of August, 2005.

LAW OFFICES OF THOMAS JACOBS By______________________________

Copy of the foregoing mailed/delivered this 17Th day of August, 2005 to: Hon. Roslyn O. Silver United States District Judge Sandra Day O'Connor U.S. Courthouse, Suite 624 401 West Washington Street, SPC 59 Phoenix, AZ 85003 Glenn McCormick, Esq. U.S. ATTORNEYS OFFICE Two Renaissance Square 40 North Central Avenue, Suite 660 Phoenix, Arizona 85004-4408 Justine Kozac U.S. Probation Offices 401 West Washington Space 7, Suite 160 Phoenix, AZ 85003-2119

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Juan Felix, #82106-008\ CCA P.O. Box 6300 Florence, AA 85232

Case 2:04-cr-00403-ROS

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