Motion Picture Association of America v. CrystalTech Web Hosting Inc.

Filing 175

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Motion Picture Association of America v. CrystalTech Web Hosting Inc. Doc. 175 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 Theron M Hall III T h e H a l l F i r m p. c. State Bar Number 019114 One Renaissance Square Two North Central Avenue Suite 735 Phoenix, AZ 85004 (602) 2226699 Fax (602) 4432221 Jd N Attorney for Defendant IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA United States of America, Plaintiff, v. Ruben Navarro-Ruiz, Defendant Case No. 07-CR-634-PHX-DGC MOTION TO RESET SENTENCING DATE Defendant Ruben Navarro-Ruiz, through undersigned counsel, respectfully requests that this Court change the sentencing date of July 2, 2007. Mr. Navarro-Ruiz and defense counsel are very appreciative that the Motion to Expedite was granted, and understand that the July 2, 2007 sentencing date would be exactly at three months (i.e. the likely maximum of the plea offer). Unfortunately, defense counsel has long planned to be out-of-town from June 27, 2007 until July 8, 2007. Defense counsel understands that the Court's calendar is very busy, but nonetheless requests that the sentencing be reset to a date earlier than June 27, 2007. -1Dockets.Justia.com 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 Assistant U.S. Attorney Raymond K. Woo 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 31st day of May, 2007. s/ Theron M Hall III Theron M Hall III -2-

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