Free Motion to Continue Sentencing - 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, No. CR04-403-02-PHX-ROS UNOPPOSED MOTION TO CONTINUE SENTENCING HEARING [11Th Request]

JUAN FELIX, Defendant.

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 July 17th, 2006. This request for a continuance is made for the following reason(s): 1. Counsel for defendant will be out of town in a pre-planned family vacation

from July 6, 2006 to July 14, 2006. Therefore, undersigned counsel requests that this matter be continued for at least fourteen (14) days. There are developments in the case that may occur prior to the sentencing date, which counsel will need to be aware of

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before proceeding with the sentencing. Counsel will be out of contact with his office from July 7 ­ July 16, 2006, and will be unable to assimilate any change of circumstances prior to presenting the case at sentencing if the matter proceedings on July 17, 2006. 2. Undersigned counsel's office has spoken with Assistant U.S. Attorney Glenn Undersigned

McCormick, who has stated that he has no objection to the continuance.

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 11th requested extension. 4. This motion is made in the interests of justice, and not for mere purpose of delay. RESPECTFULLY SUBMITTED this 5th day of July, 2006.

LAW OFFICES OF THOMAS JACOBS

By_____________________________ Thomas Jacobs, Esq. Attorney for Defendant Copy of the foregoing has been served Electronically or by other means this 5thth day of July, 2006 to:

Hon. Rosalyn O. Silver Email: [email protected] Glenn McCormick, Esq. Email: [email protected]

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Copy of the foregoing mailed/delivered this 5thth day of June, 2006 to: Justine Kozac U.S. Probation Offices 401 West Washington Space 7, Suite 160 Phoenix, AZ 85003-2119 Juan Felix, #82106-008 C/o CCA P.O. Box 6300 Florence, Az 85232

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Case 2:04-cr-00403-ROS

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