Free Motion to Extend Time - District Court of Arizona - Arizona

1 JON M. SANDS Federal Public Defender 2 District of Arizona 3 850 W. Adams Street, Suite 201 Phoenix, Arizona 85007 4 Telephone: (602) 382-2755 5 DOUGLAS A. PASSON, # 017423 [email protected] 6 Asst. Federal Public Defender Attorney for Defendant 7 IN THE UNITED STATES DISTRICT COURT 8 9 10 11 12 13 14 15 16 17 18 19 vs. Juan Garcia-Aguilar, Defendant. United States of America, Plaintiff, DISTRICT OF ARIZONA CR-02-371-PHX-SMM MOTION TO EXTEND TIME TO FILE OBJECTIONS TO PRESENTENCE REPORT (First request)

Defendant Juan Garcia-Aguilar, through undersigned counsel, respectfully requests that this Court extend the deadline for filing objections to the presentence report, from the current date of October 5, 2006, for a period of 14 days.

20 Undersigned counsel received the initial presentence report on October 3, 2006. 21 Undersigned counsel requires additional time to confer with his client and determine 22 what, if any, objections need to be filed to the report. Mr. Garcia-Aguilar requests 23 that this Court set a new deadline for objections that is two (2) weeks from this date, 24 pursuant to Rule 32(f)(1) of the Federal Rules of Criminal Procedure (stating that the 25 26 27 28 parties must submit objections to the presentence report within fourteen days after receiving the report). By this motion, Mr. Garcia-Aguilar requests the fourteen days to which he is entitled under Rule 32(f)(1).

Case 2:02-cr-00371-SMM

Document 30

Filed 10/05/2006

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Mr. Garcia-Aguilar is scheduled for sentencing on October 30, 2006. At

2 this time, he is not seeking to continue the sentencing date. 3 Respectfully submitted this 5th day of October 2006. 4 5 6 7 8 9 10 Copy of the foregoing transmitted by CM/ECF for filing this 5th day 11 of October 2006 to: 12 Clerk's Office 13 United States District Court Sandra Day O'Connor Courthouse 14 401 W. Washington Phoenix, Arizona 85003 15 Raynette Logan 16 Assistant U.S. Attorney United States Attorney's Office 17 Two Renaissance Square 18 40 N. Central Avenue, Suite 1200 Phoenix, Arizona 85004-4408 19 20 Copy mailed to: JON M. SANDS Federal Public Defender s/ Douglas A. Passon DOUGLAS A. PASSON Asst. Federal Public Defender

Darrin Harris 21 United States Probation Officer Sandra Day O'Connor Courthouse 22 401 W. Washington, Suite 160 23 Phoenix, Arizona 85003 24 Juan Garcia-Aguilar Defendant 25 26 27 28 2 s/ Douglas A. Passon Douglas A. Passon

Case 2:02-cr-00371-SMM

Document 30

Filed 10/05/2006

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