Free Response to Motion - District Court of Arizona - Arizona

1 JON M. SANDS Federal Public Defender 2 District of Arizona 3 850 W. Adams Street, Ste. 201 Phoenix, Arizona 85007 4 Telephone: (602) 382-2753 5 Donna Lee Elm, #12127 Asst. Federal Public Defender 6 Attorney for Defendant [email protected] 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Juan Perez-Robles briefly and respectfully responds to the Government's motion for a continuance to brief the merits. The Defense appreciates vs. Juan Perez-Robles, Defendant. United States of America, Plaintiff, No. CR-03-1267-PHX-FJM RESPONSE TO GOVERNMENT'S MOTION TO CONTINUE SENTENCING AND REQUEST FOR LEAVE TO FILE ADDITIONAL MEMORANDUM REGARDING AMELINE REMAND IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA

22 the Government's withdrawal of its original argument. Further, as represented by 23 Ms. Ireland, the Defense does not object to the requested continuance nor further 24 briefing. Mr. Perez-Robles does, however, ask the Court to limit that continuance. 25 Bear in mind that, presuming that the Court agrees with the application of Lopez26 Solis to this case, Mr. Perez-Robles would have already served more time than 27 would be ordered in a corresponding new sentence; hence, lengthy delay is not in 28 ...

Case 2:03-cr-01267-FJM

Document 60

Filed 07/10/2006

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1 the interest of justice. The Government sought five (5) days continuance, and that 2 is acceptable to the Defense. 3 Respectfully submitted: July 10, 2006. 4 JON M. SANDS Federal Public Defender 5 6 7 8 9 Copy of the foregoing transmitted by ECF this 10th day of 10 July, 2006, to: 11 JACKI IRELAND 12 Assistant United States Attorney Two Renaissance Square 13 40 North Central Avenue Suite 1200 14 Phoenix, Arizona 85004-4408 15 16 Copy mailed to: 17 KELLY HEITKAM United States Probation 18 Sandra Day O'Connor U.S. Courthouse 401 W. Washington Street 19 Suite 410 Phoenix, Arizona 85003 20 21 JUAN PEREZ-ROBLES Defendant 22 s/Donna Lee Elm 23 DONNA LEE ELM 24 25 26 27 28
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s/Donna Lee Elm DONNA LEE ELM Asst. Federal Public Defender

Case 2:03-cr-01267-FJM

Document 60

Filed 07/10/2006

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