Free Motion to Continue Dispositional Hearing - District Court of Arizona - Arizona

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26

Joy Bertrand PO Box 2734 Scottsdale, AZ 85252-2734 AZ State Bar No. 024181 Office ­ 480-656-3919 Cell ­ 414-687-4932 Fax ­ 480-361-4694 Email ­ [email protected] www.joybertrandlaw.com Attorney for the Defendant

IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA ) No. 04-CR-113-PHX-MHM ) ) MOTION TO CONTINUE ) DISPOSITION HEARING ) (THIRD) ) CARL WATSON, ) Defendant. ) _______________________________________) NOW COMES the Defendant, Carl Watson, by his attorney, Joy Bertrand, to ask this Court to extend time to file PSR objections and to continue sentencing, currently set for June 10, 2008. As further grounds therefore, the Defendant submits the following: This matter is set to be disposed of with the Defendant's new case, United States v. Watson, 07CR1241. In conducting the presentence investigation, the Defense and United States Probation Office learned that the Defendant was treated for psychiatric disorders with the Federal Bureau of Prisons and while detained at the Central Arizona Detention Center. On June 24, 2008, United States Probation turned over these records, which showed contrary, limited information about the Defendant. The Defendant UNITED STATES, Plaintiff,

Case 2:04-cr-00113-MHM

Document 133

Filed 08/22/2008

Page 1 of 3

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26

continues to seek additional records from both the Bureau of Prisons and the Central Arizona Detention Center. Therefore, the Defendant asks this Court to continue the Defendant's June 10, 2008 dispositional hearing for 45 days, in tandem with his request in the new case. . On about August 21, 2008, AUSA Allison Bachus stated to Defense Counsel that the Government has no objection to this request. The Court will find attached a proposed order. Respectfully submitted this 22nd day of August, 2008. s/Joy Bertrand Joy Bertrand Attorney for Carl Watson

Case 2:04-cr-00113-MHM

Document 133

Filed 08/22/2008

Page 2 of 3

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 s/Joy Bertrand Joy Bertrand Attorney for Defendant CERTIFICATE OF SERVICE On July 7, 2008, I, Joy Bertrand, attorney for the Defendant, Carl Watson, filed the Defendant's Motion to Continue Disposition Hearing (Second) and proposed order with the Arizona District Court's electronic filing system. Based on my training and experience with electronic filing in the federal courts, it is my understanding that a copy of this request will be electronically served upon opposing counsel, Alison Bachus, upon its submission to the Court. Respectfully submitted this Seventh day of July, 2008.

Case 2:04-cr-00113-MHM

Document 133

Filed 08/22/2008

Page 3 of 3