Opinion
Case No. 3:98-cr-00038-15
08-14-2012
UNITED STATES OF AMERICA v. TONI TULLOCH
Sabin R. Thompson (6876) Prochaska Thompson Quinn & Ferraro, P.C.
Senior District Judge Nixon
MOTION OF DEFENDANT TONI TULLOCH
TO RESCHEDULE AUGUST 10, 2012 HEARING FOR RE-SENTENCING
The Defendant, Toni Tulloch, has her re-sentencing hearing set to be heard on Friday, August 10, 2012 at 10:00 a.m.
By this motion, Defendant asks the Court to enter an Order that re-schedules the hearing on Ms. Tulloch's re-sentencing until a later date. The grounds for this motion are that counsel for Ms. Tulloch, Sabin R. Thompson, and counsel for the government, AUSA Sunny Koshy, have agreed that a later date in the latter part of September, 2012, would be a better hearing date under the circumstances of this particular case. The reasons for the requested hearing date in the latter part of September are the conflicts in the schedules of the two attorneys as well as the need to allow time for the completion of certain necessary tasks prior to the hearing. The undersigned has spoken with AUSA Sunny Koshy about this and AUSA Koshy has authorized him to state that the government has no objection to the requested continuance.
Wherefore, Defendant Toni Tulloch prays that her re-sentencing hearing be re-scheduled to a later date, preferably in the latter part of September, 2012.
Respectfully submitted,
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Sabin R. Thompson (6876)
Prochaska Thompson Quinn & Ferraro, P.C.
Certificate of Service
I hereby certify that a copy of the foregoing Motion has been served upon the following individuals by United States Mail, first-class postage pre-paid on this the 8th day of August, 2012: Sunny A.M. Koshy
Assistant U.S. Attorney
United States Probation and Pre-trial Services
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Sabin R. Thompson