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

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BLUMBERG & ASSOCIATES

Bruce E. Blumberg
BLUMBERG & ASSOCIATES
_____________________

45 West Jefferson, Suite 210 Phoenix, Arizona 85003
Office: (602) 277-6180 Fax: (602) 271- 4119

Attorney for Defendant Arizona State Bar Number 010779

UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA

UNITED STATES OF AMERICA, Plaintiff, vs. HARVEY SLONIKER., Defendant

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45 West Jef ferson, Suite 210 Phoenix, Arizona 85003

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) Case No: 04-CR-820-PHX-FJM ) ) MOTION TO CONTINUE SENTENCING ) ) (First Request) ) ) ) ) )

COMES NOW, Defendant, Harvey Sloniker, by and through undersigned counsel, and respectfully requests that this Honorable Court enter an Order continuing the Sentencing currently set for April 3, 2006 at 3:00 p.m. for no more than two (2) weeks for the following reason: 1. Due to the complexity issues involved in the sentencing. 2. To permit defense counsel additional time to complete defendant's sentencing memorandum and to respond to the government's sentencing memorandum which was submitted on March 24, 2006. 3. Additionally, this brief continuance is requested for the reason that U.S. Probation Officer, Guillermo Pena, was delayed, through no fault of his own, in getting a draft of the pre-sentence report out to all parties thus shortening the time available to file any objections. 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 of from an Order based thereon.

Case 2:04-cr-00820-FJM

Document 231

Filed 03/27/2006

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BLUMBERG & ASSOCIATES

WHEREFORE, defendant, Harvey Sloniker, respectfully requests that Sentencing be continued for a period of 2 weeks.

RESPECTFULLY SUBMITTED, this 27th day of March, 2006.

BLUMBERG & ASSOCIATES

By:

s/Bruce E. Blumberg

CERTIFICATE OF SERVICE
I hereby certify that on this date, 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: Michael Bresnehan, Rachel Hernandez, Gary Restaino, Jeanette Alvarado, Thomas Hoidal, Ivan Mathew, Gregory Parzych, and the Honorable Frederick Martone.

11
45 West Jef ferson, Suite 210 Phoenix, Arizona 85003

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Case 2:04-cr-00820-FJM

Document 231

Filed 03/27/2006

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