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

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

MICHAEL B. BERNAYS State Bar No. # 007057 3839 N. 3rd Street, Suite 400 Phoenix, Arizona 85012 Phone: 602-254-5544 Fax: 602-254-9263 Attorney for Defendant UNITED STATED DISTRICT COURT DISTRICT OF ARIZONA UNITED STATES OF AMERICA Plaintiff, vs. SHEILA M. ISABELL, et al., Defendant ) ) ) ) ) ) ) ) Case No.: CR 03-1082-001-PHX-MHM

MOTION TO CONTINUE THE JULY 11, 2007, SENTENCING

Defendant, Sheila M. Isabell, through counsel, Michael B. Bernays, hereby moves the Court to continue sentencing currently scheduled for July 11, 2007, for a period of approximately 21 days on the grounds that counsel for Ms. Isabell is attending a preplanned/pre-paid CLE Seminar in San Diego, California and a family vacation for July 10 through July 22, 2007. AUSA John Lopez will be out of town the week of July 23, 2007. For the Court's edification counsel is also scheduled to be out of state August 2 through August 4, 2007 to assist in the move of his daughter to college in California. Counsel would therefor request that this matter be scheduled for August1, 2007, if at all possible. Counsel has spoken with John Lopez, Assistant United States Attorney assigned to this matter, and has explained the situation to him. Counsel has been authorized by Mr. Lopez to state that the government does not oppose this motion. Counsel would therefore move the Court to continue this matter to a time convenient to Court and counsel.

Case 2:03-cr-01082-MHM

Document 90

Filed 06/25/2007

Page 1 of 2

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

Excludable delay pursuant to 18 U.S.C. § 3161(h)(8)(A) and (B)(iv) will occur as a result of this motion. RESPECTFULLY SUBMITTED this 22nd day of June, 2007.

s/ Michael B. Bernays Michael B. Bernays 3839 N. 3rd Street, Suite 400 Phoenix, Arizona 85012 Attorney for Defendant Copy of the foregoing e-mailed Via CM/EFC this 22nd day of June, 2007, to: John Lopez Assistant U.S. Attorney 40 North Central Avenue, Ste. 1200 Phoenix, AZ 85004-4408 By: s/ Michael B. Bernays

Case 2:03-cr-01082-MHM

Document 90

Filed 06/25/2007

Page 2 of 2