Cygnus Systems, Inc. v. Microsoft Corporation, et al

Filing 408

Cygnus Systems, Inc. v. Microsoft Corporation, et al

Doc. 408

1 JON M. SANDS F eder al Public Defender 2 Distr ict of Arizona th 3 2285aSouth 4 Avenue, Suite E Yum , Arizona 85364 4 Telephone: [phone] MATTHEW A. JOHNSON, CA# 207984 Assistant Federal Public Defender 6 Attor ney for Defendant 7 IN THE UNITED STATES DISTRICT COURT 8 DISTRICT OF ARIZONA 9 10 11 12 13 14 15 16 17 18 Defendant, Gerardo Solis-Perez by and through counsel undersigned 19 r espectfully moves this Court for an order continuing the sentencing in the above 20 matter from May 21, 2007 for a period of not less than thirty (30) days, for the 21 following justifiable reason: 22 1. Counsel currently has twenty four (24) sentencing hearings set for May 21, 23 2007 in various courtrooms in the United States District Court in Phoenix Arizona 24 making it extremely difficult to effectively represent each client. 25 Assistant U.S. Attorney, Beverly R. McCallum, has been contacted and has 26 expr essed no objection to this continuance. United States Probation has been also 27 28 been advised of the requested continuance. vs. (First Request) Gerardo Solis-Perez, Defendant. United States of America, Plaintiff, No. CR 07- 00140-001-PHX-MHM MOTION TO CONTINUE SENTENCING

Dockets.Justia.com

1

It is expected that excludable delay under Title 18 U.S.C. § 3161(h)(1)(I) may

2 occur as a result of this motion or from an order based thereon. 3 Respectfully Submitted: May 4, 2007. 4 JON M. SANDS F eder al Public Defender 5 6 7 8 9 10 Copy of the foregoing deliver ed this 4th day of 11 May, 2007, via ECF to: 12 Bever ly R. McCallum 13 Assistant United States Attorney 14 15 COPY mailed to: 16 United States Probation 17 Sandra Day O'Connor U.S. Courthouse 401 W. Washington Street 18 Suite 410 Phoenix, Arizona 85003 19 Copy mailed to: 20 21 Defendant 22 G. Rodriguez _________________________ 23 G. Rodriguez 24 25 26 27 28
\ C on tS en tM T N

s/ Matthew A. Johnson ______________________________ MATTHEW A. JOHNSON Assistant Federal Public Defender