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

Filing 312

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M D Y Industries, LLC v. Blizzard Entertainment, Inc. et al D o c . 312 1 JON M. SANDS F eder al Public Defender 2 Distr ict of Arizona 4th Avenue, Suite 3 2285aS.Arizona 85364 #E Yum , 4 Telephone: (928) 314-1780 5 Juan L. Rocha Az. State Bar No.025039 6 Assistant Federal Public Defender Attor ney for Defendant 7 IN THE UNITED STATES DISTRICT COURT 8 DISTRICT OF ARIZONA 9 10 11 12 13 14 15 16 vs. Jose Alfredo Molina-Herrera, Defendant. Defendant, by and through undersigned counsel, hereby requests that this United States of America, Plaintiff, No. CR07-1087-PHX-NVW MOTION TO CONTINUE SENTENCING 17 Cour t enter an order continuing the sentencing in this matter from, December 10, 18 2007, for a period of thirty (30) days and extending the deadline for filing 19 defendant's objections to the presentence report for thirty (30) days, with all 20 subsequent deadlines pertaining to the report adjusted accordingly. The reason for 21 22 this continuance is that counsel received the pre-sentence report in this matter on 23 November 13,2007. Due to logistical constraints, counsel has only recently been 24 able to discuss said pre-sentence report with his client. Upon discussion, issues 25 r egar ding this report have arisen. Consequently, counsel needs additional time to 26 possibly file objections to the presentence report. 27 28 /// 1 There has been no dilatory conduct and the parties maintain an open line of 2 communication at all times. 3 Defense counsel's office has contacted Assistant U.S. Attorney, Timothy F. 4 Andr ews who has expressed no objection to the requested continuance. U.S. 5 Pr obation Office has also been contacted regarding the requested continuance. 6 It is expected that excludable delay under 18 U.S.C. 3161(h)(1)(F) may 7 8 occur as a result of this motion or from an order based thereon. 9 10 11 12 13 14 15 16 Copy of the foregoing th 17 deliver ed this 28 day of November, 2007, to: 18 Tim Andrews 19 Assistant United States Attorney 20 United States Probation 21 22 MAILED TO Defendant 23 24 25 26 27 28 Respectfully Submitted: November 28, 2007. JON M. SANDS F eder al Public Defender /s/Juan L. Rocha ______________________________ Juan L. Rocha Assistant Federal Public Defender

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