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 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 Alfonso Guadiana-Caro, through counsel, and hereby moves this Court to continue the Sentencing hearing, which is presently scheduled for Monday, August 15, 2005 at 9:30 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 9th day of August, 2005.

_________________________ Eugene Márquez Attorney for Defendant

Case 2:03-cr-00883-PGR

Document 95

Filed 08/09/2005

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ORIGINAL and COPY of the foregoing filed this 9th day of August, 2005 to: Clerk of the Court United States District Court 401 West Washington Street Phoenix, Arizona 85003 COPY of the foregoing sent via email this 9th day of August, 2004 to: Lisa Roberts Assistant United State's Attorney United States Attorney's Office 40 North Central Avenue, Suite 1200 Phoenix, Arizona 85004

Case 2:03-cr-00883-PGR

Document 95

Filed 08/09/2005

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