Free Motion to Continue - District Court of Arizona - Arizona

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LAW OFFICE OF NEIL C. LABARGE
NEIL C. LABARGE State Bar No. 13920 11 W . Jefferson St., #2 Phoenix, AZ 85003 (602) 252-4090 FAX (602) 252-2111 Attorney for Defendant Guillen

IN THE UNITED STATES DISTRICT COURT 7 DISTRICT OF ARIZONA 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Defendant. Comes now defendant, through attorney Neil C. LaBarge, and respectfully requests that the court continue the Sentencing currently set for Monday, November 14, 2005 for a period of three weeks. This motion is based on the following grounds: 1) Defense counsel needs additional time to prepare for sentencing and submit objections to the Pre-Sentence Report. 2) AUSA Lisa Settel is currently out of the office until November 14, 2005. In Ms. Settel's absence, undersigned counsel has been advised by her assistant that the unit supervisor, AUSA Rachael Hernandez, would have no objection to this motion. 3) Undersigned counsel left a message for USPO Sharie Lutt earlier this date, but does not know her position as of the time of filing this motion. It is anticipated that excludable delay may occur pursuant to 18 USC 3161(h)(8)(A) as a result of this motion or an order based thereon. v. EDIL ORLANDO GUILLEN-PINEDA, U.S.A., Plaintiff, MOTION TO CONTINUE SENTENCING, AND ORDER No. CR03-1188-PHX-NVW

Case 2:03-cr-01188-NVW

Document 340

Filed 11/09/2005

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Respectfully submitted this date: November 9, 2005. LAW OFFICE OF NEIL C. LABARGE

3 4 ________________________________ 5 NEIL C. LABARGE 6 7 8 Original filed with the following via ECF this date: November 9, 2005. 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -2Filed 11/09/2005 Hon. Neil V. Wake 401 W. Washington St. Phoenix, AZ 85003 Lisa Settel, AUSA 40 N. Central Ave., #1200 Phoenix, AZ 85004 Clerk of the Court 401 W. Washington St. Phoenix, AZ 85003 Copies e-mailed to the following on this date: November 9, 2005. Hon. Neil V. Wake [email protected] Copies mailed to the following on this date: November 9, 2005.

Case 2:03-cr-01188-NVW

Document 340

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1 2 3 4 5 6 7 8 9 10 11 v. 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 ___________________________________ Honorable Neil V. Wake, U.S. District Court, District of Arizona -3Filed 11/09/2005 THE COURT, having reviewed the Motion to Continue Sentencing, and good cause appearing, IT IS ORDERED granting the motion and continuing the Sentencing to _____________________, 2005 at _______ o' clock in Phoenix, AZ. IT IS FURTHER ORDERED that excludable delay in this case under 18 USC 3161 will commence on __________________ for a total of ______ days. SO ORDERED THIS DATE: __________________________. Defendant. ORLANDO PALMA, U.S.A., Plaintiff, No. CR03-188-9-PHX-NVW ORDER IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA

Case 2:03-cr-01188-NVW

Document 340

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