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, CR04-0403-02-TUC-ROS UNOPOSSED MOTION TO CONTINUE SENTENCING HEARING [10TH 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 June 19, 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 June 17, 2006 to June 24, 2006. Therefore, undersigned counsel requests that this matter be continued for thirty (30) days. 2. Undersigned counsel's office has spoken with Assistant U.S. Attorney

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Glenn McCormick, who has stated that he has no objection to the continuance. Also, U.S. Attorney Glenn McCormick will be out of town. The available dates agreed upon by the parties are July 3-5, 2006. 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 tenth requested extension. 4. This motion is made in the interests of justice, and not for mere purpose of delay. WHEREFORE, undersigned counsel requests that the sentencing hearing date of this matter be continued to a mutually agreed upon date. RESPECTFULLY SUBMITTED this 8th day of June, 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 8th day of June, 2006 to:

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

Copy of the foregoing mailed/delivered this

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8th 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 CCA P.O. Box 6300 Florence, AA 85232

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Case 2:04-cr-00403-ROS

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