MDY Industries, LLC v. Blizzard Entertainment, Inc. et al

Filing 166

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1 2 3 4 5 6 R. ANTONIO FELIX A t t o rn e y at Law 1 4 5 South Sixth Avenue T u c s o n , Arizona 85701 Phone: 520-629-9069 Fax: 520-629-8229 a n t o n io @ f e l ix l a w .c o m A Z Bar Number: 019075 A t t o r n e y for Defendant Angel-Mendez UNITED STATES DISTRICT COURT 7 DISTRICT OF ARIZONA 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Delivery by electronic or other means to: The Honorable Frank R. Zapata AUSA Beverly Anderson U.S. Probation Officer Garret C. Pfalmer COMES NOW Mr. Angel-Mendez, by counsel, and moves to continue the June 30, 2006 sentencing in this matter to allow the parties time to prepare responses to the defense objections to the presentence report. Defense counsel required additional time prepare the objections because (1) he moved his office at the end of May and has spent a disproportionate amount of time on administrative tasks, and (2) defense counsel's notes regarding the video depositions were focused on trial issues, and it took counsel longer than expected to find the testimony needed for guideline objection purposes. AUSA Beverly Anderson has no objection to this motion. A continuance of thirty (30) days is requested to allow the government and probation time to respond to the objections. RESPECTFULLY SUBMITTED 25 June 2006 s / R. UNITED STATES OF AMERICA, CR 04­2300­TUC­FRZ (BPV) Plaintiff, v. LEOBIGILDO ANGEL-MENDEZ, et al (THIRD REQUEST) Defendants. STIPULATED MOTION TO CONTINUE SENTENCING Antonio Felix Attorney for Leobigildo Angel-Mendez

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