Free Motion to Continue - District Court of Arizona - Arizona

1 JON M. SANDS Federal Public Defender 2 850 W. Adams, Ste 201 Phoenix, Arizona 85007 3 Telephone: 602-382-2700 4 CELIA M. RUMANN State Bar # 015993 5 Asst. Federal Public Defender Attorney for Defendant 6 [email protected] 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 vs. Linda Gallegos, United States of America, Plaintiff, No. CR-01-204-PHX-SMM MOTION TO CONTINUE ADMIT/DENY HEARING (1st Request) IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA

Defendant. Defendant, Linda Gallegos, through undersigned counsel, asks this Court to continue the admit/deny hearing set for October 3, 2005, to another day convenient to the court's calendar. The reason for this request is defense counsel has an early morning doctor's appointment in North Scottsdale and fears she may not make it to the hearing on time. Counsel also request the time to attempt to resolve the matter without a hearing. Defense counsel has contacted the Assistant U.S. Attorney assigned to this case, Darcy Cerow, who has no objection to this motion. Excludable delay under 18 U.S.C. § 3161(h)(1)(F) and (8)(A) will occur as a result of this motion or from an order based thereon. Respectfully submitted: September 30, 2005. JON M. SANDS Federal Public Defender s/Celia M. Rumann CELIA M. RUMANN Assistant Federal Public Defender

Case 2:01-cr-00204-SMM

Document 35

Filed 09/30/2005

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1 Copy of the foregoing transmitted by CM/ECF for filing this 30th day 2 of September, 2005, to: 3 CLERK'S OFFICE United States District Court 4 Sandra Day O'Connor Courthouse 401 W. Washington 5 Phoenix, Arizona 85003 6 Darcy Cerow Assistant U.S. Attorney 7 United States Attorney's Office Two Renaissance Square 8 40 N. Central Avenue, Suite 1200 Phoenix, Arizona 85004-4408 9 Copy mailed to: 10 11 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 Linda Gallegos 12 Defendant s/Celia M. Rumann
\cnt admit.deny hrg

Case 2:01-cr-00204-SMM

Document 35

Filed 09/30/2005

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