Free Motion to Continue - District Court of Arizona - Arizona

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Barbara L. Hull 86 West University, Suite 101A Mesa, Arizona 85201 State Bar No. 011890 Telephone: (480)834-0002 Facsimile: (480)834-0003 Attorney for Defendant
IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA

UNITED STATES OF AMERICA, Plaintiff, vs. BRANDI LYNN McCRORY, Defendant

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Case No.: CR-04-777-PHX-DGC MOTION TO CONTINUE (Assigned to The Honorable David G. Campbell) (No oral argument requested.)

Defendant, through undersigned counsel, respectfully requests that this Court enter its Order continuing the sentencing currently set in this matter for Monday, November 21, 2005. The defense recently received the Presentence Report and needs additional time to review it with Ms. McCrory. It contains, at first blush, a number of inaccuracies and required corrections. Likewise, counsel has consulted with Mr. Pacheco of the AUSA's office, and he indicated that he would likewise utilize additional time to review the PSR and file necessary motions.

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Case 2:04-cr-00777-DGC

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Filed 11/18/2005

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Defense counsel has communicated with the Assistant United States Attorney's office concerning this motion, and the government, through Mr. Pacheco, has no objection to the requested continuance. It is not anticipated that excludable delay under 18 U.S.C. §3161(h)(8)(A) will result from this motion and any Order arising herefrom. RESPECTFULLY SUBMITTED this 18th day of November, 2005.
____/S/__Barbara L. Hull_______________

Barbara L. Hull, Attorney for Ms. McCrory Original filed electronically this date. Courtesy copy provided via email this date to: The Honorable David G. Campbell United States District Court 401 West Washington Street Phoenix, Arizona 85003-0001 at: [email protected] Andrew Pacheco, Esq. Assistant U.S. Attorney Two Renaissance Square, Suite 1200 40 North Central Avenue Phoenix, Arizona 850034-4408 at: [email protected] /S/__Barbara L. Hull_____

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Case 2:04-cr-00777-DGC

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Filed 11/18/2005

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