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

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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 ) ) 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 3, 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. According to United States Probation Office John Mulavey, these records have been received by the probation office, but not yet turned over to the Defense. The Defense had previously asked probation to share these records. Case 2:04-cr-00113-MHM Document 129 Filed 05/28/2008 Page 1 of 3 UNITED STATES, Plaintiff,

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On May 27, 2008, Mr. Mulavey stated to counsel that he would turn over these records. Counsel believes that these records could contain information relevant to the Defendant's sentence and disposition under 18 U.S.C. § 3553(a), to wit: the history and character of the Defendant and his need for medical care. Therefore, the Defendant asks this Court to continue the Defendant's June 3, 2008 sentencing for thirty days. Counsel has a previously-scheduled vacation out of town, leaving June 30 and returning July 8, 2008, so she would respectfully ask the Court to set the sentencing hearing for after July 8, 2008. On May 27, 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 28th day of May, 2008. s/Joy Bertrand Joy Bertrand Attorney for Carl Watson

Case 2:04-cr-00113-MHM

Document 129

Filed 05/28/2008

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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 May 28, 2008, I, Joy Bertrand, attorney for the Defendant, Carl Watson, filed the Defendant's Motion to Continue Disposition Hearing 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 28th day of May, 2008.

Case 2:04-cr-00113-MHM

Document 129

Filed 05/28/2008

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