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

1 JON M. SANDS Federal Public Defender 2 District of Arizona 3 850 W. Adams, Suite 201 Phoenix, Arizona 85007 4 Telephone: (602) 382-2721 Facsimile: (602) 382-2800 5 JEANETTE E. ALVARADO, #016111 6 Asst. Federal Public Defender Attorney for Defendant 7 [email protected] 8 9 10 11 12 13 14 15 16 17 18 19 20 21 vs. (Second Request) Robert Shinn, et al., Defendant. Robert Shinn, by and through undersigned counsel, respectfully moves this Court for an order continuing the sentencing in the above matter from November 20, 2006 for a period of at thirty days (30) days. This continuance is requested due to Mr. Shinn's co-defendant, Tye Ray Sloniker sentencing of November 13, 2006 United States of America, Plaintiff, IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA No. CR-04-0820-PHX-FJM MOTION TO CONTINUE SENTENCING

22 being continued to December 12, 2006. Per agreement with the government, and in 23 line with the terms of Mr. Shinn's plea agreement, Mr. Shinn is to be sentenced last. 24 A continuance of thirty days would be one week after the last of the codefendants 25 sentencing December 12, 2006. 26 Rachel Hernandez, Assistant United States Attorney, has been contacted 27 28 regarding the requested continuance and she has no objection. Guillermo Pena has been advised of this motion.

Case 2:04-cr-00820-FJM

Document 291

Filed 11/09/2006

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It is expected that excludable delay under Title 18 U.S.C. § 3161(h)(1)(I)

2 will occur as a result of this motion or from an order based thereon. 3 Respectfully submitted: November 9, 2006. 4 5 6 7 8 s/Jeanette E. Alvarado JEANETTE E. ALVARADO Asst. Federal Public Defender JON M. SANDS Federal Public Defender

9 I hereby certify that on November 9, 2006, I electronically transmitted the attached document to the Clerk's Office using the ECF System for filing and transmittal to the 10 following ECF registrants: 11 CLERK'S OFFICE 12 United States District Court Sandra Day O'Connor Courthouse 13 401 W. Washington Phoenix, Arizona 85003 14 Copies mailed to: 15 16 GUILLERMO PENA United States Probation 17 Sandra Day O'Connor Courthouse 401 W. Washington, Suite 160 18 Phoenix, Arizona 85003 19 ROBERT SHINN Defendant 20 s/Jeanette E. Alvarado 21 22
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Case 2:04-cr-00820-FJM

Document 291

Filed 11/09/2006

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