Free Motion to Continue Dispositional Hearing - District Court of Arizona - Arizona

1 LAW OFFICE OF NEIL C. LABARGE 2 3 4 5
Attorney for Defendant Ram irez NEIL C. LABARGE State Bar No. 13920 11 W . Jefferson St., #2 Phoenix, AZ 85003 (602) 252-4090 FAX (602) 252-2111

6 7 8 9 U.S.A., 10 Plaintiff, 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Defendant. Comes now defendant, through attorney Neil C. LaBarge, and respectfully requests that the court continue the Disposition Hearing currently set for Wednesday, September 12, 2007 for a period of thirty (30) days. This motion is based on the following grounds: 1) Undersigned counsel is still gathering sentencing letters to submit to the court. The court has the discretion to impose a concurrent or consecutive sentence to the sentence defendant is currently serving, and therefore such mitigating information is very important. 2) AUSA Darcy Cerow has no objection. It is anticipated that excludable delay may occur pursuant to 18 USC 3161(h)(8)(A) as a result of this motion or an order based thereon. Respectfully submitted this date: September 6, 2007. LAW OFFICE OF NEIL C. LABARGE S/Neil C. LaBarge ________________________________ Case 2:02-cr-00289-JAT Document 33 NEIL C. LABARGE Filed 09/06/2007 Page 1 of 2 CARLOS RAMIREZ-DUARTE, v. MOTION TO CONTINUE DISPOSITION HEARING No. CR02-289-PHX-JAT IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA

1 Original filed with the following via ECF this date: September 6, 2007. 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 -2Filed 09/06/2007 Clerk of the Court 401 W. Washington St. Phoenix, AZ 85003 Copies e-mailed to the following on this date: September 6, 2007. Hon. James A. Teilborg [email protected]

Case 2:02-cr-00289-JAT

Document 33

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