Free Motion to Continue - District Court of Arizona - Arizona

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Eugene Márquez, Esq. State Bar No. 018079 EUGENE MARQUEZ, P.L.C. 3030 North Central Avenue, Suite 608 Phoenix, Arizona 85012 Telephone: (602) 631-9595 Facsimile: (602) 274-8585 E-Mail: [email protected] Attorney for Defendant IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA ) ) ) Plaintiff, ) ) vs. ) ) JORGE GONZALES-SOTO, ) ) Defendant. ) ____________________________________) UNITED STATES OF AMERICA,

Case No. CR-03-883-PHX-PGR MOTION TO CONTINUE SENTENCING HEARING

COMES NOW Defendant Jorge Gonzales-Soto, through counsel, and hereby moves this Court to continue the Sentencing hearing, which is presently scheduled for Monday, December 12, 2005 at 9:00 a.m., for a period of 120 days. The reason for this motion to continue is that the terms of Mr. Gonzales-Soto's Plea Agreement require that the sentencing be deferred for a period of twenty-four months; since his entry of the plea agreement, just over one year has elapsed, thus requiring that he remain in this "deferred status" for a longer period of time. Defense counsel has consulted with the Assistant U.S. Attorney, Lisa Roberts, concerning this matter, and she has no objection to this motion.

DATED this 8th day of December, 2005.

/s Eugene Márquez _________________________ Eugene Márquez Attorney for Defendant

Case 2:03-cr-00883-PGR

Document 97

Filed 12/08/2005

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1 2 3 4 5 6 7 8 ORIGINAL and of the foregoing filed via CM/ECM this 8th day of December, 2005 to: Clerk of the Court United States District Court 401 West Washington Street Phoenix, Arizona 85003 COPY of the foregoing sent via the CM/ECF email delivery system this 8th day of December, 2005 to:

9 Lisa Roberts Assistant United State's Attorney 10 United States Attorney's Office 40 North Central Avenue, Suite 1200 11 Phoenix, Arizona 85004 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

Case 2:03-cr-00883-PGR

Document 97

Filed 12/08/2005

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