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

1 JON M. SANDS Federal Public Defender 2 850 West Adams Street, Suite 201 Phoenix, Arizona 85007 3 Telephone: 602-382-2721 4 JEANETTE E. ALVARADO (#016111) Asst. Federal Public Defender 5 Attorney for Defendant 6 7 8 9 10 11 12 13 14 15 Defendant, Robert Joseph Ramirez, is scheduled for an admit/deny 16 before this Court on Tuesday, February 21, 2006, at 2:30 p.m. It is respectfully 17 requested that the disposition hearing be set for the same time, and Mr. Ramirez will 18 waive preparation of a disposition memorandum and accept the oral disposition 19 recommendation to be made by the US Probation Officer, Michael G. Wimmer. 20 The parties have reached an agreement in exchange for Mr. Ramirez' 21 anticipated admission to Allegation A. This agreement is that Mr. Ramirez' 22 supervised release would be revoked and he would serve a sentence of time served, 23 with no supervised release to follow. Mr. Ramirez has a steady job to return to upon release. It is the same 24 25 employment he has held for many years. Undersigned counsel avows that through 26 conversation she has had with Mr. Ramirez' employer, Bob Davis, Mr. Ramirez has 27 a job waiting for him, as well as a place to live in the back-house of his employer's 28 residential property. vs. Robert Joseph Ramirez, Defendant. United States of America, Plaintiff, No. PT00-140-PHX-JAT MOTION TO SET DISPOSITION HEARING (First Request) IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA

Case 2:00-pt-00140-JAT

Document 35

Filed 02/16/2006

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Therefore, it is respectfully requested that this Court set the disposition Defense counsel has contacted the Assistant U.S. Attorney assigned to

2 for the same date and time as the currently set Admit/Deny Hearing. 4 this case, Darcey Cerow, and U.S. Probation Officer Michael Wimmer, who have no 5 objection to this motion. 6 8 9 10 11 12 13 Copy of the foregoing delivered 14 this 16th day of February, 2005, to: 15 DARCY CEROW Assistant U.S. Attorney 16 United States Attorney's Office Two Renaissance Square 17 40 N. Central Avenue, Suite 1200 Phoenix, Arizona 85004-4408 18 Copy mailed to: 19 MICHAEL WIMMER 20 United States Probation Office Sandra Day O'Connor U.S. Courthouse 21 401 W. Washington Street Suite 410 22 Phoenix, Arizona 85003 23 ROBERT JOSEPH RAMIREZ Defendant 24 s/Jeanette E. Alvarado 25 JEANETTE E. ALVARADO Assistant Federal Public Defender 26 27 28
\M otionSetDispositionHearing

Excludable delay under 18 U.S.C. § 3161(h)(1)(F) and (8)(A) will occur Respectfully submitted: February 16, 2006. JON M. SANDS Federal Public Defender s/Jeanette E. Alvarado JEANETTE E. ALVARADO Assistant Federal Public Defender

7 as a result of this motion or from an order based thereon.

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Case 2:00-pt-00140-JAT

Document 35

Filed 02/16/2006

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