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Document 171
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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CR-20612-SEITZ UNITED STATES OF AMERICA, Plaintiff, vs. HASSAN SAIED KESHARI, Defendant. ________________________________/ AGREED MOTION TO CONTINUE SENTENCING AND FOR ADDITIONAL TIME TO FILE OBJECTIONS TO THE PSI
Hassan Saied Keshari, by and through undersigned counsel, files this Motion to Continue Sentencing and to Extend Time to File Objections to the PSI and states as follows: 1. 2. 3. Mr. Keshari pled guilty and his sentencing is currently set for April 8, 2009. The PSI for Mr. Keshari was received on Tuesday, March 10, 2009. Undersigned counsel has been in trial since February 17, before the
Honorable Alan S. Gold in the case of United States v. Ali Shaygan. That case concluded on March 12, 2009. 4. Mr. Keshari is scheduled to testify in the case of his co-defendant, Traian
Bujduveanu. Accordingly, we are requesting that the sentencing be continued until after that trial which is scheduled for mid-May. 5. AUSA Melissa Damian agrees to the relief requested in this motion.
D A VID O SC A R M A R KU S , PLLC
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Case 1:08-cr-20612-PAS
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WHEREFORE it is respectfully requested that this Honorable Court continue the sentencing until the end of May. Respectfully submitted,
DAVID OSCAR MARKUS, PLLC 169 East Flagler Street, Suite 1200 Miami, FL 33131 Tel: (305)379-6667 Fax: (305)379-6668 www.markuslaw.com
By:
/s/ David Oscar Markus DAVID OSCAR MARKUS Florida Bar Number 119318 DMarkus@MarkusLaw.com
CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was e-filed this 13th day of March 2009, and served on all appropriate parties through that system.
D A VID O SC A R M A R KU S , PLLC
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