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Theron M Hall III The Hall Law Firm p.c. One Renaissance Square Two North Central Avenue Suite 735 Phoenix, AZ 85004 (602) 2226699 Fax (602) 4432221 Arizona Bar No. 019114
Attorney for Defendant
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA
United States of America, Plaintiff, v.
Case No. CR03-854-4-PHX-LOA MOTION TO CONTINUE SENTENCING
Kristina Nichole Ingles,
Defendant Defendant Kristina Ingles, through undersigned counsel, respectfully requests that this Court continue the July 23, 2007 sentencing date for a period of three weeks. Today, defense counsel will be filing under seal a lengthy list of objections to the Presentence Investigation Report. Defense counsel and Defendant Kristina Ingles understand that additional time will be needed by U.S. Probation Officer Beth Stewart to prepare a response. Due to Ms. Stewart's busy schedule (i.e. she
Case 2:03-cr-00854-LOA
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has 15 reports due this month, including five due this week alone) she has requested an additional three weeks to prepare a response to the objections. Assistant U.S. Attorney Paul Rood does not oppose this motion. It is expected that excludable delay under Title 18 U.S.C. Section 3161(h)(1)(F) may occur as a result of this motion or from an order based thereon. Respectfully submitted this 17th day of July, 2007. s/ Theron M Hall III Theron M Hall III
Case 2:03-cr-00854-LOA
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