Free Motion to Continue Sentencing - 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 vs. Juan Perez-Robles, Defendant. Juan Perez-Robles respectfully moves this Court for an order continuing (First Request) United States of America, Plaintiff, No. CR-03-1267-PCT-FJM MOTION TO CONTINUE SENTENCING IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA

19 the sentencing in the above matter from May 31, 2006 for a period of at least three 20 (3) weeks. The basis for this requested continuance is undersigned counsel needs 21 additional time to consult with her client. The Defendant speaks Spanish and 22 undersigned counsel needs the assistance of an interpreter to help communicate with 23 24 25 26 27 . . . 28 . . . ... the Defendant. Jacki Ireland, Assistant U.S. Attorney, has been contacted and has no objection to this continuance.

Case 2:03-cr-01267-FJM

Document 54

Filed 05/30/2006

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It is expected that excludable delay under Title 18 U.S.C. §

2 3161(h)(1)(I) may occur as a result of this motion or from an order based thereon. 3 Respectfully submitted: May 30, 2006. 4 5 6 7 8 9 Copy of the foregoing transmitted by ECF this 30th day of 10 May, 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 22 Defendant 23 s/Donna Lee Elm DONNA LEE ELM 24 \ContSentMTN 25 26 27 28
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JON M. SANDS Federal Public Defender s/Donna Lee Elm DONNA LEE ELM Asst. Federal Public Defender

Case 2:03-cr-01267-FJM

Document 54

Filed 05/30/2006

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