Free Motion to Continue - District Court of Arizona - Arizona

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PAUL K. CHARLTON United States Attorney District of Arizona JOHN R. LOPEZ IV Assistant United States Attorney Two Renaissance Square 40 North Central Avenue Phoenix, Arizona 85004 State Bar No. 019182 [email protected] Telephone: (602) 514-7500 UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA United States of America, Plaintiff, v. Andrew Taylor, Defendant. ) ) ) ) ) ) ) ) ) )

NO. CR-04-809-PHX-NVW MOTION TO CONTINUE EVIDENTIARY HEARING re: RESTITUTION (First Request)

The United States moves to continue the evidentiary hearing in this matter regarding 16 the amount of restitution due victim Bharat Lal, for approximately 1 week. The hearing 17 currently is set for January 13, 2006, at 2:00 p.m. The government seeks this continuance 18 because both Assistant United States Attorneys assigned to the matter have family 19 commitments on January 13; neither raised his plans when this Court set the hearing because 20 each incorrectly assumed the other would be available to appear at the hearing. Additionally, 21 U.S. Probation Officer Shelley Gonshak-Peters, the Pre-Sentence Report Writer in this 22 matter, advises that as of the date of this motion she has yet to receive the billing records 23 from Mr. Lal's former attorneys in connection with his efforts to collect the debt owed him 24 by defendant. Ms. Gonshak-Peters expects those records later this week, and will forward 25 copies to counsel for both parties to review thereafter. Defense counsel, Mr. Cameron A. 26 Morgan, has no objection to the continuance.

Case 2:04-cr-00809-NVW

Document 122

Filed 01/09/2006

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Excludable delay under 18 U.S.C. § 3161(h) may occur as a result of this motion or an order based thereon. RESPECTFULLY SUBMITTED this 9 th day of January, 2006.

PAUL K. CHARLTON United States Attorney District of Arizona S/ John R. Lopez IV JOHN R. LOPEZ IV Assistant United States Attorney
I hereby certify that on January 9, 2006, 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: Mr. Cameron A. Morgan 4295 N. 75 th Street Scottsdale, AZ 85251-3695 S/ John R. Lopez IV

Case 2:04-cr-00809-NVW

Document 122

Filed 01/09/2006

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