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

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JON M. SANDS Federal Public Defender PETER M. RAPTIS Assistant Federal Public Defender Arizona State Bar No. 016712 407 West Congress Street, Suite 501 Tucson, Arizona 85701-1355 Telephone: (520) 879-7500 Facsimile: (520) 879-7601 Attorney for Defendant [email protected] PMR/asp 02/23/06 IN THE UNITED STATES DISTRICT COURT

8 FOR THE DISTRICT OF ARIZONA 9 United States of America, 10 Plaintiff, 11 v. 12 Christian Omar Hernandez-Lopez, 13 Defendant. 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 4. 3. 2. ) ) ) ) ) ) ) ) ) ) NO: CR-02-0130-PHX-JMR MOTION TO CONTINUE DISPOSITION HEARING OF MARCH 8, 2006 (Third Request)

Defendant, Christian Omar Hernandez-Lopez, through counsel, requests a 30day continuance of the Disposition Hearing set for March 8, 2006, at 9:25 a.m. before the Honorable John M. Roll. This request for continuance is made for the following reasons: 1. Counsel has reviewed the Pre-Sentence Report and is investigating the facts of prior law enforcement contact alleged in the report. On this date, in a separate motion, counsel also requested a 30-day extension of the sentencing hearing presently scheduled for March 8, 2006 in Mr. Hernandez-Lopez' related case, CR-050313-TUC-JMR. As the records are needed in order to resolve both cases, counsel requests that these cases be scheduled consecutively. Assistant United States Attorney, Irene C. Feldman, has been contacted and has no objection to this request. Margaret Pritchard, United States Probation Office, has been contacted and has no objection to this request.

Case 2:02-cr-00130-JMR

Document 41

Filed 02/28/2006

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RESPECTFULLY SUBMITTED this 28th day of February 2006. JON M. SANDS Federal Public Defender

/s/ PETER M. RAPTIS

____________________________ PETER M. RAPTIS Assistant Federal Public Defender Copy of the foregoing Motion to Continue Disposition of March 8, 2006 provided this 28th day of February 2006 to: THE HONORABLE JOHN M. ROLL United States District Court By Hard Copy IRENE C. FELDMAN, Assistant United States Attorney's Office By Electronic Filing MARGARET PRITCHARD United States Probation Office By Hard Copy

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Case 2:02-cr-00130-JMR

Document 41

Filed 02/28/2006

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