Free Motion to Continue - 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 12/1/05 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 3. 2. ) ) ) ) ) ) ) ) ) ) NO: CR-02-0130-PHX-JMR MOTION TO CONTINUE DISPOSITION HEARING OF DECEMBER 12, 2005 (Second Request)

Defendant, Christian Omar Hernandez-Lopez, through counsel, requests a 60day continuance of the Disposition Hearing set for December 12, 2005, at 9:15 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; said information has not been received by counsel and is necessary to properly defend this case. On this date, in a separate motion, counsel also requested a 60-day extension of the sentencing hearing presently scheduled for December 12, 2005 in Mr. Hernandez-Lopez' related case, CR-05-0313-TUCJMR. 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.

Case 2:02-cr-00130-JMR

Document 39

Filed 12/01/2005

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Margaret Pritchard, United States Probation Office, has been contacted and has no objection to this request.

RESPECTFULLY SUBMITTED this 1st day of December, 2005. 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
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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 December 12, 2005 provided this 1st day of December, 2005 to: THE HONORABLE JOHN M. ROLL United States District Court By Hard Copy & E-Mail IRENE C. FELDMAN, Assistant United States Attorney's Office By Electronic Filing MARGARET PRITCHARD United States Probation Office By Hard Copy

Case 2:02-cr-00130-JMR

Document 39

Filed 12/01/2005

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