USA v. Newcomb et al, 4:12-cr-00009, No. 46 (W.D.Mo. Apr. 27, 2012)

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USA v. Newcomb et al, 4:12-cr-00009, No. 46 (W.D.Mo. Apr. 27, 2012)

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Case: 4:12-cr-00009-RWS Doc. #: 46 Filed: 04/27/12 Page: 1 of 3 PageID #: 235
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`UNITED STATES DISTRICT COURT
`EASTERN DISTRICT OF MISSOURI
`EASTERN DIVISION
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`Case. No. 4:12-cr-00009 RWS DDN
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`UNITED STATES OF AMERICA,
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`Plaintiff,
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`v.
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`SANDRA L. BEHE,
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`Defendant.
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`MOTION TO CONTINUE SENTENCING OF DEFENDANT SANDRA L. BEHE
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`Defendant Sandra L. Behe, by and through her attorney, Robert T. Haar, hereby moves to
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`continue the date of her sentencing. In support of this motion, defendant states as follows:
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`1.
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`On March 2, 2012, defendant Behe entered a plea of guilty to one count of
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`introducing adulterated prescription drugs into interstate commerce. The Court set sentencing
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`for May 25, 2012.
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`2.
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`At the time of the plea, undersigned counsel advised the Court that he believed
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`that his son’s graduation ceremony was scheduled for that day. Counsel has since confirmed that
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`his son will be graduating from the College of the Holy Cross in Worcester, Massachusetts on
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`May 25.
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`3.
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`In order to permit counsel to attend the ceremony, defendant respectfully moves
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`that her sentencing be continued, preferably to some date in June. Counsel is scheduled to begin
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`a multi-week trial before the Honorable Richard Webber beginning July 9, 2012.
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`4.
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`The present motion is made in good faith and is not made for purposes of
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`unnecessary delay. While defendant may at the time of sentencing present legal argument
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`Case: 4:12-cr-00009-RWS Doc. #: 46 Filed: 04/27/12 Page: 2 of 3 PageID #: 236
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`regarding certain aspects of the presentence report, defendant does not contemplate presenting
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`any testimony.
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`5.
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`Assistant United States Attorney Andrew Lay has advised counsel that he has no
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`objection to this request.
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`WHEREFORE, the defendant Sandra L. Behe respectfully requests that this Honorable
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`Court continue her sentencing until June 2012.
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`HAAR & WOODS, LLP
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`/s/ Robert T. Haar
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`Robert T. Haar - #30044MO
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`1010 Market Street, Suite 1620
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`St. Louis, Missouri 63101
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`(314) 241-2224
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`(314) 241-2227 Telecopier
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` edmofiling@haar-woods.com
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` Attorneys for Defendant Sandra L. Behe
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`Case: 4:12-cr-00009-RWS Doc. #: 46 Filed: 04/27/12 Page: 3 of 3 PageID #: 237
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`CERTIFICATE OF SERVICE
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`I hereby certify that on the 27th day of April 2012, the foregoing was filed electronically
`with the Clerk of the Court to be served by operation of the Court’s electronic filing system upon
`the following:
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`/s/ Robert T. Haar
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`Andrew J. Lay
`Assistant United States Attorney
`111 South 10th Street, Suite 20.333
`St. Louis, Missouri 63102
`andrew.lay@usdoj.gov
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