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

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Theron M Hall III The Hall Law Firm p.c. One Renaissance Square Two North Central Avenue Suite 735 Phoenix, AZ 85004 (602) 222­6699 Fax (602) 443­2221 Arizona Bar No. 019114

Attorney for Defendant

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA

United States of America, Plaintiff, v.

Case No. CR03-854-4-PHX-LOA MOTION TO CONTINUE SENTENCING

Kristina Nichole Ingles,

Defendant Defendant Kristina Ingles, through undersigned counsel, respectfully requests that this Court continue the July 23, 2007 sentencing date for a period of three weeks. Today, defense counsel will be filing under seal a lengthy list of objections to the Presentence Investigation Report. Defense counsel and Defendant Kristina Ingles understand that additional time will be needed by U.S. Probation Officer Beth Stewart to prepare a response. Due to Ms. Stewart's busy schedule (i.e. she

Case 2:03-cr-00854-LOA

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Filed 07/17/2007

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has 15 reports due this month, including five due this week alone) she has requested an additional three weeks to prepare a response to the objections. Assistant U.S. Attorney Paul Rood does not oppose this motion. It is expected that excludable delay under Title 18 U.S.C. Section 3161(h)(1)(F) may occur as a result of this motion or from an order based thereon. Respectfully submitted this 17th day of July, 2007. s/ Theron M Hall III Theron M Hall III

Case 2:03-cr-00854-LOA

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Filed 07/17/2007

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