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 Attorney for Defendant IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA United States Of America, Plaintiff, v. Christian Omar Hernandez-Lopez, Defendant. ) ) ) ) ) ) ) ) ) ) NO: CR-02-0130-PHX-JMR MOTION TO CONTINUE DISPOSITION HEARING OF SEPTEMBER 20, 2005 (First Request)

Defendant, Christian Omar Hernandez-Lopez, through counsel, requests a 6014 day continuance of the Disposition Hearing set for September 20, 2005, at 9:00 a.m. 15 before the Honorable John M.. Roll. This request for continuance is made for the 16 following reasons: 17 1. 18 19 20 2. 21 22 23 24 25 3. 26 27 28 Assistant United States Attorney, Irene Feldman, has no objection to the 60-day continuance. As the records are needed in order to resolve both cases, counsel requests that these cases be scheduled consecutively. On this date, in a separate motion, counsel also requested a 60-day extension of the sentencing hearing presently scheduled for September 20, 2005 in Mr. Hernandez-Lopez' related case, CR-05-0313-TUCJMR. 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.

Case 2:02-cr-00130-JMR

Document 37

Filed 09/12/2005

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RESPECTFULLY SUBMITTED this 12th day of September, 2005. 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 September 20, 2005 provided this 12th day of September, 2005 to: THE HONORABLE JOHN M. ROLL United States District Court By Hard Copy & E-Mail IRENE FELDMAN, Assistant United States Attorney's Office By Electronic Filing ALICIA PINEDA United States Probation Office By Hard Copy

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Case 2:02-cr-00130-JMR

Document 37

Filed 09/12/2005

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