Affidavit Of Counsel Delayed Filing Of Motion To Continue Sentencing (Page 2 of 2) in pdf

Affidavit Of Counsel Delayed Filing Of Motion To Continue Sentencing Page 2

scheduled for September 27, 2005, in Pima County Superior Court, as to which the

State disclosed three critical cooperating witnesses (formerly co-defendants) on

Thursday, September 22, 2005. Affiant’s office has been directing considerable

resources toward preparing for that trial, and adjusting to disclosure of substantial

new evidence on the eve of trial.

4. As a result of the foregoing, Affiant and his staff overlooked the need to continue

the pending Sentencing Hearing in this matter until September 23, 2005. The

request for continuance was therefore made at a late date, and Affiant apologizes

for the inconvenience.

WHEREFORE, undersigned counsel requests that the sentencing hearing date

of this matter be continued to next convenient court date.

RESPECTFULLY SUBMITTED this 26th day of September, 2005.

LAW OFFICES OF THOMAS JACOBS

By_____________________________

Thomas Jacobs, Esq.

Attorney for Defendant

Copy of the foregoing

mailed/delivered this

26th day of September, 2005 to:

Hon. Roslyn O. Silver

United States District Judge

Sandra Day O’Connor U.S.

Courthouse, Suite 624

401 West Washington Street, SPC 59

Phoenix, AZ 85003

Glenn McCormick, Esq.

U.S. ATTORNEYS OFFICE

Two Renaissance Square

40 North Central Avenue, Suite 660

Phoenix, Arizona 85004-4408

Case 2:04-cr-00403-ROS

Document 102

Filed 09/26/2005

Page 2 of 2

Affidavit Of Counsel Delayed Filing Of Motion To Continue Sentencing Page 2