Free Motion to Continue - District Court of Arizona - Arizona

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Theron M Hall III O n e E a s t C a m e l b a c k Road Suite 550 Phoenix, AZ 85012 (602) 222­6699 Fax: (480) 926­3419 Arizona Bar No. 019114

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Attorney for Defendant Juan Carlos Lizarraga-Espinoza

IN THE UNITED STATES DISTRICT COURT 8 FOR THE DISTRICT OF ARIZONA 9 10 United States of America, 11 Plaintiff, 12 v. 13 Juan Carlos Lizarraga-Espinoza, 14 et al. 15 Defendant 16 17 18 19 20 21 22 23 24 25 on September 12, 2005, thus conflicting with the date and time of this sentencing; and 2) Defense counsel has had a serious family medical emergency over the last least thirty (30) days. Defense counsel requests this continuance for two reasons: 1) Defense counsel also has a sentencing before the Honorable Susan R. Bolton at 1:00 p.m. Counsel for defendant Juan Carlos Lizarraga-Espinoza, respectfully requests that this Court continue the September 12, 2005 sentencing date for a period of at Case No. CR-04-1127-001-PHX-EHC MOTION TO CONTINUE SENTENCING (First Request)

Case 2:04-cr-01127-EHC

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Filed 09/07/2005

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two-and-a-half weeks, and needs additional time to prepare for sentencing in this matter. Assistant U.S. Attorney Emory Hurley 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 7th day of September, 2005.

s/ Theron M Hall III Theron M Hall III

Case 2:04-cr-01127-EHC

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Filed 09/07/2005

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