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

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MICHAEL B. BERNAYS State Bar No. #007057 3839 N. 3rd Street, Suite 400 Phoenix, Arizona 85012 Phone: 602-254-5544 Fax: 602-254-9263 E-mail: [email protected] Attorney for Defendant UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA UNITED STATES OF AMERICA, Plaintiff, vs. MARGARET MOLTER, Defendant. ) ) ) ) ) ) ) ) ) ) No. CR 04-00539-PHX-MHM MOTION TO CONTINUE AUGUST 3, 2007, SENTENCING

The Defendant, Margaret Molter, through counsel Michael B. Bernays, hereby hereby moves the Court to continue sentencing currently scheduled for August 3, 2007, on the grounds that counsel for Ms. Molter is scheduled to be out of state August 2 through August 4, 2007 to assist in the move of his daughter to college in California. Counsel would therefore request that this matter be continued to a date convenient to the Court and counsel. Counsel has checked with the government and both parties would suggest August 24, 2007, as a date which would work for them. Undersigned counsel has spoken with Howard Sukenic, Assistant U.S. Attorney assigned to this matter, who has stated he has no objection to this motion. Anticipating that counsel for Mr. Tullo might join this motion, counsel also spoke with Michael D. Kimerer, who similarly has no objection. Counsel would therefore move the Court to grant this motion.

Case 2:04-cr-00539-MHM

Document 228

Filed 07/11/2007

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RESPECTFULLY SUBMITTED this 9th day of July, 2006.

/s Michael B. Bernays Copy of the foregoing e-mailed via ECF this 9th day of July, 2006 to: Howard Sukenic Assistant United States Attorney Two Renaissance Square 40 North Central, Ste. 1200 Phoenix, AZ 85003 David C. Derickson 3636 North Central, Ste. 1150 Phoenix, AZ 85012 Attorney for Defendant John R. Wolfe Michael D. Kimerer 221 East Indianola Phoenix, AZ 85012 Attorney for Defendant Angelo Tullo Dave Appleton 8711 East Pinnacle Peak Rd., #109 Scottsdale, AZ 85255-3517 Attorney for Defendant Gene Monteleone Jess A. Lorona 40 North Central, Ste. 2800 Phoenix, AZ 85004 Attorney for Defendant James Nova /s Michael B. Bernays

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Case 2:04-cr-00539-MHM

Document 228

Filed 07/11/2007

Page 2 of 2