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

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JON M. SANDS Federal Public Defender JOSEPH A. DUARTE Assistant Federal Public Defender State Bar No. 010603 2450 South 4th Avenue, Suite 400 Yuma, Arizona 85232 Telephone: (928) 314-1780 Attorney for Defendant IN THE UNITED STATES DISTRICT COURT

7 FOR THE DISTRICT OF ARIZONA 8 United States of America, 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 /s/ Joseph A. Duarte 28 Case 2:02-cr-00132-MHM JOSEPH A. DUARTE Assistant Federal Public Defender Document 40 Filed 11/21/2006 Page 1 of 2 ) ) Plaintiff, ) ) vs. ) ) Jose Perez-Acosta, ) ) Defendant. ) __________________________________ ) NO. CR-02-132-PHX-MHM MOTION TO CONTINUE DISPOSITION HEARING (Defendant's First Request)

It is expected that excludable delay under Title 18 U.S.C. § 3161(h)(1)(I) may occur as a result of this motion or from an order based thereon. Defendant, Jose Perez-Acosta, by and through counsel undersigned, hereby makes his request for a thirty (30) day continuance of the disposition hearing which was scheduled for Monday, November 20, 2006, at 10:45 a. m. A continuance is necessary for the reason that additional time is needed to prepare for sentencing on the underlying case and disposition report, both of which call for extraordinarily lengthy sentences. Contact was made with Assistant United States Attorney Raynette Logan who does not oppose the continuance. Based on the above reason, Defendant hereby requests a continuance of the current dispositional hearing in the instant case. RESPECTFULLY SUBMITTED this 21st day of November, 2006 . JON M. SANDS Federal Public Defender thirty (30) day

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Copy to: Raynette Logan Assistant United States Attorney Phoenix, Arizona

Case 2:02-cr-00132-MHM

Document 40 2

Filed 11/21/2006

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