Free Motion to Expedite - District Court of Arizona - Arizona

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Martin Lieberman, #007442 MARTIN LIEBERMAN, P.C. 3839 North Third Street, Ste. 400 Phoenix, Arizona 85012 [email protected] Telephone: (602) 254-5544 Fax: (602) 254-9263 IN THE UNITED STATES DISTRICT COURT IN AND FOR THE DISTRICT OF ARIZONA ) ) United States of America, ) CR04-0539 PHX-MHM ) ) MOTION TO EXPEDITE SENTENCING Plaintiff, ) ) vs. ) [Hon. Mary Murguia] ) ) Allan Guttentag (04) ) ) Defendant. ________________________________ ) The Defendant, Allan Guttentag, through undersigned counsel, hereby moves the Court to expedite his sentencing, currently scheduled for June 7, 2007, for the reason that undersigned counsel has recently been appointed by the governor to be the State Capital PostConviction Public Defender. As such, undersigned counsel expects to be closing his private practice and assuming his new role effective May 1, 2007. Assistant United States Attorney Howard Sukenic has been contacted regarding this motion and has authorized counsel to state that he does not oppose this request. Additionally, undersigned counsel and Mr. Sukenic have determined the following dates/times to be mutually convenient and would request that the sentencing be accelerated to one of the following dates, if it is convenient to the court: April 18, 2007 (all day), April 19, 2007 (all day), April 23, 2007 (afternoon only), April 24, 2007 (all day), April 25, 2007 (all day), April 26, 2007 (morning only), and April 30, 2007 (all day). Excludable delay under 18 U.S.C. §3161(h)(1)(f) will occur as a result of this motion or an order based thereon.

Case 2:04-cr-00539-MHM

Document 152

Filed 03/19/2007

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RESPECTFULLY SUBMITTED this 19th day of March , 2007. MARTIN LIEBERMAN, P.C. /s/ Martin Lieberman By: Martin Lieberman, #007442 3839 North Third Street, Ste. 400 Phoenix, Arizona 85012 Attorney for Defendant Allan Guttentag I hereby certify that on March 19, 2007, I electronically transmitted the attached document to the Clerk's Office using the ECF system for filing and transmittal of Notice of Electronic Filing to all ECF registrants associated with this case. /s/ C. Woodruff

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Case 2:04-cr-00539-MHM

Document 152

Filed 03/19/2007

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