Free Motion to Continue - District Court of Arizona - Arizona

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TIMOTHY C. HOLTZEN Attorney at Law 245 W. Roosevelt St. Phoenix, Arizona 85003 State Bar No. 004723 (602) 799-6336 (602) 368-9140 fax Attorney for Defendant

UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA ) ) ) ) ) ) ) ) ) ) No. CR 03-1205-PHX-PGR MOTION TO CONTINUE REVOCATION EVIDENTIARY HEARING (First Request)

8 United States of America, 9 10 12 13 14
v. Plaintiff,

11 Kirk Patrick St. John,
Defendant.

The defendant, through undersigned counsel, moves this Court to continue the

15 Revocation Evidentiary Hearing set for August 28, 2006 at 1:30 p.m., to a date one 16 month later or as soon thereafter as this Court's calendar permits. The defendant is not 17 in custody and resides outside of the State of Arizona. 18
The reason for this request is that additional information is needed by the

19 defense to conduct an evidentiary hearing, as well as the parties' continuing efforts to 20 resolve this matter without the necessity of a revocation evidentiary hearing. 21
Undersigned counsel has contacted the Assistant U.S. Attorney assigned to this

22 case, Darcy Cerow, and she has no objection to this request. Undersigned counsel has 23 also contacted the assigned Probation Officer, Leigh Anne Gibbons, and she has no 24 objection to the requested continuance. 25 26 27 28
Timothy C. Holtzen Timothy C. Holtzen Attorney for Defendant RESPECTFULLY SUBMITTED this 25 th day of August 2006.

Case 2:03-cr-01205-PGR

Document 37

Filed 08/25/2006

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Copy of the served by ECF electronic filing this 25th day of August 2006 to: Darcy Cerow Assistant U.S. Attorney Leigh Anne Gibbons United States Probation Officer and mailed to: Kirk Patrick St. John Defendant

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Case 2:03-cr-01205-PGR

Document 37

Filed 08/25/2006

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