Free Motion to Continue Dispositional Hearing - District Court of Arizona - Arizona

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The Law Office of Mark F. Willimann, LLC Mark F. Willimann, AZ Bar No. 017556 P.O. Box 91010 Tucson, AZ 85752 Tel: (520) 579-6622 Fax: (520) 203-0203 [email protected] Attorney for Defendant

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA UNITED STATES OF AMERICA, Plaintiff, vs. JESUS ROSAS-ARREDONDO, Defendant.

CR 08-127-TUC-CKJ CR 04-131-001-PHX-CKJ MOTION TO CONTINUE SENTENCING/DISPOSITION (FIRST REQUEST)

Mr. Rosas-Arredondo, by and through undersigned counsel, does hereby file this Motion to Continue Sentencing/Disposition currently set for June 10, 2008. While reviewing Mr. Rosas's Presentence Report with him, counsel noticed an issue that he did not originally spot when he originally reviewed this document. The issue involves category points being assessed when a juvenile is not provided an attorney when being charged with felony offenses. Assistant United States Attorney Monte Clausen has been made aware of counsel's concerns, and he has no objection to this requested continuance. Mr. Rosas-Arredondo fully expects to have his Objection to the Presentence Report ready by this Monday, June 9, 2008, as such; the government and the U.S.
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Case 2:04-cr-00131-CKJ

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Filed 06/04/2008

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Probation Department should be given ample opportunity to address Mr. Rosas's concerns; hence, Mr. Rosas respectfully requests a 30-day continuance. Wherefore, Mr. Rosas-Arredondo respectfully requests that this Court continue his Sentencing/Disposition Hearing for 30 days. Respectfully submitted this 4th day of June 2008. s/ Mark F. Willimann Mark F. Willimann Representing Mr. Rosas-Arredondo

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Case 2:04-cr-00131-CKJ

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