Free Motion to Continue - District Court of Arizona - Arizona

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Eugene Márquez, Esq. State Bar No. 018079 EUGENE MARQUEZ, P.L.C. 3030 North Central Avenue, Suite 608 Phoenix, Arizona 85012 Telephone: (602) 631-9595 Facsimile: (602) 274-8585 Attorney for Defendant IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA ) ) ) Plaintiff, ) ) ) vs. ) ) MEDARDO CHAVEZ-BURGOS, ) ) Defendant. ) ____________________________________) UNITED STATES OF AMERICA,

Case No. CR-04-403-PHX-ROS MOTION TO CONTINUE SENTENCING

COMES NOW Defendant Chavez-Burgos, through undersigned counsel, and respectfully moves this Court to continue the sentencing date, which is set for August 22, 2005 for a period of four (4) ) weeks from the scheduled date or as the Court's calendar permits. The reason for this Motion to Continue Sentencing is as follows: Defense counsel has several scheduling conflicts on the scheduled date of sentencing due to a family emergency counsel's law partner is experiencing. In addition, more time is necessary because Mr. Chavez-Burgos has still not provided counsel with needed records pertaining to his sentencing. The Assistant United States Attorney, Glen McCormick, indicates the government has no objection to this motion.

DATED this 20th day of August, 2005. S/EUGENE MARQUEZ _________________________ Eugene Márquez Attorney for Defendant

Case 2:04-cr-00403-ROS

Document 98

Filed 08/21/2005

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 ORIGINAL and COPY of the foregoing filed this 21st day of August, 2005 to: Clerk of the Court United States District Court 401 West Washington Street Phoenix, Arizona 85003 COPY of the foregoing sent via e-mail this 21st day of August, 2005 to: Glen McCormick Assistant United State's Attorney United States Attorney's Office 40 North Central Avenue, Suite 1200 Phoenix, Arizona 85004

Case 2:04-cr-00403-ROS

Document 98

Filed 08/21/2005

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