Free Motion for Miscellaneous Relief - District Court of Arizona - Arizona

JON M. SANDS Federal Public Defender 2 District of Arizona 850 West Adams, Suite 201 3 Phoenix, Arizona 85007 Telephone: (602) 382-2767
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TRACY FRIDDLE, Bar Assoc. #022446 Asst. Federal Public Defender Attorney for Defendant 6 [email protected]
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IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA United States of America, Plaintiff, -vsRyan Lewis, Defendant. No. CR-04-424-PHX-FJM MOTION TO CONTINUE DEADLINE FOR FILING OBJECTIONS TO THE PRESENTENCE INVESTIGATION REPORT (1st Request; Sentencing Previously Continued Once)

Defendant, through counsel undersigned, respectfully moves that this court continue the deadline for filing objections to the presentence investigation report for a period of fourteen (14) days from the current date of November 3, 2005. Defendant requests this continuance because United States Probation Officer Sharie Lutt has indicated that additional time is needed to determine the amount of time that defendant was held in tribal custody. Officer Lutt expects to hear from tribal authorities about this matter some time next week. The presentence investigation report, therefore, will not be ready for disclosure to the parties by October 24, 2005, the current initial disclosure deadline. In light of the anticipated delay in the disclosure of the presentence investigation report, the requested continuance is necessary to afford defendant an opportunity to review the report and file any appropriate objections.

Case 2:04-cr-00424-FJM

Document 18

Filed 10/18/2005

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Undersigned counsel has spoken with the Assistant United States Attorney handling this case, Sharon Sexton, who has no objection to the requested continuance. Respectfully submitted: October 18, 2005. JON M. SANDS Federal Public Defender s/Tracy Friddle TRACY FRIDDLE Asst. Federal Public Defender

Copy of the foregoing MOTION TO CONTINUE DEADLINE FOR FILING OBJECTIONS TO THE PRESENTENCE 11 INVESTIGATION REPORT was electronically transmitted by CM/ECF system 12 this 18th day of October, 2005, to:
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Sharon Sexton Assistant U.S. Attorney 14 Two Renaissance Square, Suite 1200 40 North Central Ave. 15 Phoenix, Arizona 85004-4408
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I hereby certify that the foregoing document was mailed on 17 October 18, 2005, to the following who is not a registered participant 18 of the CM/ECF system:
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Sharie Lutt U.S. Probation Officer 20 401 West Washington Phoenix, AZ 85004
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Ryan Lewis Defendant s/Tracy Friddle
Tracy Friddle i:\lewis, r\ext time to file obj to PSR

Case 2:04-cr-00424-FJM

Document 18

Filed 10/18/2005

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