Free Motion to Continue Sentencing - District Court of Arizona - Arizona

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PAUL K. CHARLTON United States Attorney District of Arizona DANIEL R. DRAKE Assistant U.S. Attorney Two Renaissance Square 40 N. Central Avenue, Suite 1200 Phoenix, Arizona 85004-4408 Arizona State Bar No. 003781 Telephone (602) 514-7500 [email protected]

UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA United States of America, CR-04-0350-PHX-PGR Plaintiff, v. John Delo Nichols, Defendant. GOVERNMENT'S SECOND MOTION TO CONTINUE SENTENCING

The United States respectfully moves this Court to continue for two weeks the sentencing

16 presently set for June 5, 2006. Government counsel will be out of the district on June 5 and June 17 12, 2006. 18 Counsel undersigned has discussed this motion with Donald W. MacPherson, counsel for 19 defendant, and he had no objection to this motion or an order granting the relief requested. 20 Defendant is in release status under the supervision of the Pretrial Services Agency. 21 Excludable delay under 18 U.S.C. 3161(h) may occur as a result of this motion or an 22 order based thereon. 23 24 //// 25 //// 26 //// 27 28

Case 2:04-cr-00350-PGR

Document 34

Filed 05/16/2006

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/Daniel R. Drake Daniel R. Drake Donald W. MacPherson Attorney for Defendant /Daniel R. Drake Daniel R. Drake

Respectfully submitted this 16th day of May, 2006.

PAUL K. CHARLTON United States Attorney District of Arizona /S Daniel R. Drake DANIEL R. DRAKE Assistant U.S. Attorney

I hereby certify that on May 16, 2006, I electronically transmitted the attached document to the Clerk's Office using the CM/ECF system for filing and transmittal of a Notice of Electronic Filing to the following CM/ECF registrants:

I hereby certify that on May 16, 2006, I served the attached document by fax on the following person who is not a registered participant of the ECF system: Lisa Miller, United States Probation Officer

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Case 2:04-cr-00350-PGR Document 34 Filed 05/16/2006 Page 2 of 2