Free Motion to Continue - District Court of Arizona - Arizona

1 TIMOTHY C. HOLTZEN 2 245 W. Roosevelt St. 3 Phoenix, Arizona 85003
State Bar No. 004723 (602) 368-9140 fax Attorney at Law

4 (602) 799-6336 5 Attorney for Defendant 6 7 8 9 United States of America, 10 11 13 14 15
The defendant, through undersigned counsel, moves this Court to continue the v. Plaintiff, UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA ) ) ) ) ) ) ) ) ) ) No. CR 03-0974-PHX-DGC MOTION TO CONTINUE SENTENCING

12 Neil Rusty Bond,
Defendant.

16 Sentencing presently set for October 17, 2005, for at least 30 days. The reason for this 17 request is that undersigned counsel received a copy of the final draft presentence report 18 today, October 11, 2005. Just one week earlier, on October 4, 2005, a draft presentence 19 report was faxed to counsel's office while counsel was out of town in trial in a drug 20 trafficking case in the federal courthouse in Prescott, Arizona. Counsel has not had 21 sufficient time to review the report and prepare objections. Pursuant to General Order 22 98-10 of this Court, the parties are entitled to more time to review the draft presentence 23 report and lodge objections to the report. 24 / / / 25 / / / 26 / / / 27 28 1

Case 2:03-cr-00974-DGC

Document 145

Filed 10/11/2005

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The Assistant U.S. Attorney assigned to this case, Michelle Hamilton-Burns,

2 has no objection to this request.
RESPECTFULLY SUBMITTED this 11 th day of October 2005.

\s Timothy C. Holtzen Timothy C. Holtzen Attorney for Defendant

7 Copy of the foregoing served by ECF filing this 11th day of October 2005 to: 8 9 Joscelyn N. Funnié Assistant U.S. Attorney 10 Two Renaissance Square
Michelle Hamilton-Burns

11 Phoenix, Arizona 85004-4408 12 Copy of the foregoing mailed 13 14 Defendant 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Neil Rusty Bond

40 N. Central Avenue, Suite 1200

this 11th day of October 2005 to:

2

Case 2:03-cr-00974-DGC

Document 145

Filed 10/11/2005

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