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) 382-2700 5 JANE L. McCLELLAN AZ State Bar No. #015902 6 Asst. Federal Public Defender [email protected] 7 Attorney for Defendant 8 IN THE UNITED STATES DISTRICT COURT 9 10 11 12 13 14 15 16 17 Timothy Wayne Isabell, by and through undersigned counsel, 18 respectfully requests that this Court continue the sentencing in the above matter 19 from August 21, 2006, for a period of at least thirty (30) days. The basis for this 20 21 22 23 24 requested continuance is that defendant needs additional time to gather documents, including medical records, for sentencing. Further, defense counsel has several scheduling conflicts in August and needs additional time to prepare the appropriate sentencing documents for the Court. Therefore, defendant respectfully requests -vsTimothy Wayne Isabell, Defendant. United States of America, Plaintiff, MOTION TO CONTINUE SENTENCING (First Request) No. CR-03-1082-PHX-MHM DISTRICT OF ARIZONA

25 that this Court continue her sentencing hearing. John Lopez, Assistant U.S. Attorney, has been contacted and has no 26 27 objection to this continuance. 28 ////

Case 2:03-cr-01082-MHM

Document 55

Filed 07/19/2006

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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: July 19, 2006. 4 5 6 7 8 9 10 s/ Jane L. McClellan JANE L. McCLELLAN Asst. Federal Public Defender JON M. SANDS Federal Public Defender

Copy of the foregoing transmitted 11 by ECF for filing this 19th day of July, 2006, to: 12 Office 13 Clerk'sStates District Court United 14 Sandra Day O'Connor Courthouse 401 W. Washington 15 Phoenix, Arizona 85003 16 John Lopez Assistant U.S. Attorney 17 Two Renaissance Square Central 18 40 North ArizonaAve., Ste. 1200 Phoenix, 85003 19 20 Copy mailed to:

Justine Kozak 21 United States Probation Sandra Day O'Connor U.S. Courthouse 22 401 W. Washington Street 23 Suite 410Arizona 85003 Phoenix, 24 26 Timothy Wayne Isabell 25 Defendant s/ Kathy Kruckeberg 27 Kathy A. Kruckeberg 28
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Case 2:03-cr-01082-MHM

Document 55

Filed 07/19/2006

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