Free Motion to Continue - District Court of Arizona - Arizona

OSBORN MALEDON
A PR O FESSI O NA L A SSO CIA TI O N A T T O R N E Y S A T LA W

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The Phoenix Plaza 21st Floor 2929 North Central Avenue Phoenix, Arizona 85012-2793 P.O. Box 36379 Phoenix, Arizona 85067-6379 Telephone Facsimile 602.640.9000 602.640.9050

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Larry A. Hammond (004049) OSBORN MALEDON, P.A. 2929 North Central Avenue Suite 2100 Phoenix, Arizona 85012-2794 (602) 640-9000 [email protected] Attorneys for Defendant Glen Beck

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA

9 10 11 12 13 GLEN BECK, 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Attorney. This matter has recently been reassigned to Assistant United States Attorney, Ms. Darcy Cerow. Undersigned has been in touch with her and has offered
Case 2:03-cr-00890-JAT Document 55 Filed 08/02/2007 Page 1 of 3

UNITED STATES OF AMERICA, Plaintiff, vs.

Defendant.

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No. CR 03-00890-PHX-JAT

MOTION TO CONTINUE EVIDENTIARY HEARING RE: PETITION TO REVOKE PROBATION Assigned to the Honorable James A. Teilborg

The evidentiary hearing in the above-captioned matter is now scheduled on August 15, 2007. The purpose of this Motion is to request that the hearing be continued to a date in the latter half of September or early October. Several considerations support this request. First, as the Court may recall, it has been our hope that this matter might be resolved without the need for an evidentiary hearing. Mr. Beck and undersigned counsel continue to hope that this can be achieved. To that end, we have been in communication with the Probation Office and with the Office of the United States

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to provide additional documentation and to confer with her in an effort to either resolve the matter or at least to narrow the issues. Second, undersigned has encountered scheduling conflicts that have made it difficult to prepare for this hearing and to communicate with an eye toward resolution. I am serving as lead counsel in a federal death penalty case pending in the Southern District of California before the Honorable Larry A. Burns ­ United States v. Francisco Javier Arellano-Felix, Case No. 06CR2646-LAB. The Court has scheduled oral arguments on a series of pending motions for August 14, 2007, at 9:00 a.m. Additionally, we have just been advised that our presentation to the Justice Department's Capital Case Review Committee will occur in Washington, D.C. on August 20. For this reason, on behalf of Mr. Beck, counsel requests that the evidentiary hearing be rescheduled to some date acceptable to the Court in the latter half of September or October. Counsel has discussed this continuance with counsel to the United States, and she is not opposed to this continuance. RESPECTFULLY SUBMITTED this 2nd day of August, 2007. OSBORN MALEDON, P.A.

By

s/Larry A. Hammond Larry A. Hammond 2929 North Central Suite 2100 Phoenix, Arizona 85012-2794 Attorneys for Glen Beck

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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 27 28 s/Donna Toland

CERTIFICATE OF SERVICE I hereby certify that on the 2nd day of August, 2007, I electronically transmitted the attached document to the Clerk's Office using the CM/ECF System for filing and transmittal of a Notice of Electronic Filing to the following CM/ECF registrant: Darcy A. Cerow - [email protected]

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