Free Motion to Continue Dispositional Hearing - 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

BALTAZAR INIGUEZ Attorney at Law 3106 N. 16th Street Phoenix, AZ 85016-7610 Phone (602) 285-5688 Fax (602) 277-1636 [email protected] State Bar No. 006084 Attorney for Defendant UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA United States of America, Plaintiff, vs. Armando Ulyesses Espinoza, Defendant. ) No. CR 02-454-PHX-ROS ) ) ) MOTION TO CONTINUE ) DISPOSITION HEARING ) ) ) ) )

COMES NOW Defendant Armando Ulyesses, by and through his undersigned attorney, and respectfully requests this Court to continue the Disposition Hearing set on August 7, 2006 at 10:00 a.m. for approximately (60) days for the reason that defendant is currently in the custody of the State of Arizona for charges pending against him in the Superior Court. In addition, counsel has been advised by the U.S. Probation Officer that there is a Superceding Petition pending which will add to defendant's charges in the U.S. District Court.

Case 2:02-cr-00454-ROS

Document 35

Filed 08/01/2006

Page 1 of 2

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15

Let the Court be advised that the Assistant U.S. Attorney does not object to a continuance in this matter. It is expected excludable delay under Title 18 U.S.C. Section 3161 (h)(8)(A) may occur as a result of this Motion or from an Order based thereon. RESPECTFULLY SUBMITTED this 1st of August, 2006.

s/Baltazar Iniguez BALTAZAR INIGUEZ Attorney for Defendant CERTIFICATE OF SERVICE

I hereby certify that on this date, I electronically transmitted the attached 16 documents to the Clerk's Office using the CM/ECF System for filing and transmittal of Notice of Electronic filing to the following CM/ECF registrants: 17 Richard Mesh.
18 19 20 21 22 23 24 25 26 27 28

Copy of the foregoing faxed this 1st day of August, 2006, to: Michael G. Wimmer U.S. Probation Officer

Case 2:02-cr-00454-ROS

Document 35

Filed 08/01/2006

Page 2 of 2