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

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MARK PAIGE 45 West Jefferson Luhrs Tower - Suite #806 Phoenix, AZ 85003-2317 (602) 254-5457 State Bar #020902 [email protected] Attorney for Defendant

UNITED STATES DISTRICT COURT 7 8 9 10 11 12 13 14 The defendant, Jesse Moore, by and through counsel respectfully moves the Court for a 15 continuance of the presently set sentencing date of May 5, 2008 on the following grounds: 16 1. The defendant pled guilty on February 11, 2008. Sentencing was set for May 5, 2003. 17 2. Counsel met with the investigator after the plea hearing to discuss mitigation evidence 18 for sentencing. Presently, counsel and the investigator are continuing in efforts to review 19 materials gathered over the course of this matter for the purpose of mitigation. These 20 documents are quite voluminous. Additional time is needed to complete the review, 21 update necessary information and locate individuals necessary for sentencing purposes. 22 3. Consequently, counsel is requesting that this matter be continued for approximately 23 thirty (30) days. 24 4. This defendant is in custody. 25 Counsel for the Government, Roger Dokken, has no objection to this request. 26 The defendant requests a continuance of this matter to allow undersigned counsel to be 27 prepared and able to render effective assistance of counsel consistent with the Sixth Amendment 28 DISTRICT OF ARIZONA _______________________________________ ) UNITED STATES, ) No.: CR-03-764-PHX-JAT ) Plaintiff, ) ) DEFENDANT'S MOTION TO v. ) CONTINUE SENTENCING ) Jesse Moore, ) ) Defendant. ) (First Request) _______________________________________)

Case 2:03-cr-00764-JAT

Document 1269

Filed 04/15/2008

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guarantee for every defendant.

Respectfully submitted this 15th day of April, 2008. S/ Mark A. Paige MARK PAIGE Attorney for Defendant I hereby certify that on June 1, 2007, I electronically transmitted the attached document to the Clerk's Office using the CM/ECF system for filing and transmittal of a Notice of Electronic Filing to the following CM/ECF registrants: Roger Dokken Assistant U.S. Attorney [email protected] Shawn Shear U.S. Probation 401 W. Washington St. Phoenix, AZ 85003 S/ Mark A. Paige Mark A. Paige

Case 2:03-cr-00764-JAT

Document 1269

Filed 04/15/2008

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