Free Motion to Continue Sentencing - District Court of Arizona - Arizona

1 JON M. SANDS Federal Public Defender 2 District of Arizona 850 W. Adams Street, Suite 201 3 Phoenix, Arizona 85007 4 Telephone: (602) 382-2700 5 DEBORAH EULER-AJAYI State Bar No. 010537 6 Asst. Federal Public Defender Attorney for Defendant 7 [email protected] 8 9 10 11 12 13 14 15 16 -vsJeanette B. Wilcher, Defendant. Jeanette Wilcher, through undersigned counsel, moves to continue the United States Of America, Plaintiff, MOTION TO CONTINUE SENTENCING (First Request) IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA No. CR03-1098-PHX-EHC

17 sentencing currently set for July 17, 2006, for two reasons. First, defense counsel 18 has been in trial and therefore unable to meet with her client to discuss the report and 19 determine what if any objections are appropriate. Second, Mrs. Wilcher's youngest 20 daughter is getting married at the end of October. The wedding date has been set for 21 many months, and it is extremely important to Mrs. Wilcher, her daughter, and their 22 entire family that she be present for that wedding. For the foregoing reasons, a 23 continuance to the first week of November is requested. 24 Both Assistant U.S. Attorneys John Lopez and Stephen Laramore are out 25 of the office this week and so could not be contacted for their position on this request. 26 27 28

Case 2:03-cr-01098-EHC

Document 231

Filed 06/28/2006

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Excludable delay under 18 U.S.C. §3161(h)(1)(F) and (8)(A) will occur

2 as a result of this motion or from an order based thereon. Respectfully submitted: June 28, 2006. JON M. SANDS Federal Public Defender s/Deborah Euler-Ajayi DEBORAH EULER-AJAYI Assistant Federal Public Defender

9 Copy of the foregoing transmitted by ECF for filing this 28th day 10 of June, 2006, to: 11 CLERK'S OFFICE 12 United States District Court Sandra Day O'Connor Courthouse 13 401 W. Washington Phoenix, Arizona 85003 14 JOHN LOPEZ 15 Assistant U.S. Attorney United States Attorney's Office 16 Two Renaissance Square 40 N. Central Avenue, Suite 1200 17 Phoenix, Arizona 85004-4408 18 Copy mailed to: 19 JEANETTE WILCHER 20 Defendant 21 22 23 24 25 26 27 28 s/ G. Dorsey G. Dorsey

Case 2:03-cr-01098-EHC

Document 231

Filed 06/28/2006

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