UNITED STATES DISTRICT COURT
_______________ DISTRICT OF TEXAS
_________________  DIVISION

UNITED STATES OF AMERICA	                 §
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V.	                                                                 §	[NUMBER]
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[CLIENT]	                                                     §

MOTION TO EXPEDITE SENTENCING

	COMES NOW the Defendant, [CLIENT] and moves the court to expedite the sentencing in this case and set the sentencing hearing as early as practicable.  In support thereof, Defendant shows the following:
I.
	On [PLEA DATE], defendant plead guilty to --------------------, under ----U.S.C. --------.  On ----------------- he received a copy of the presentence investigation report.  He then filed a Motion to Adopt the PSIR on -----------. There are no objections or other matters to be presented to the court by the Defendant or the Government.  The sentencing hearing is scheduled presently for [SENTENCING DATE] at 8:30 a.m.  As the Defendant is incarcerated in the ______________________, it would not further any interest of the Defendant, the Government or the trial court to wait until [SENTENCING DATE] to sentence the defendant in this cause.  Defendant is aware of and understands the time afforded [HIM / HER] under Fed.R.Crim.Pro. 32 and Local Rule 10.9 and waives said additional time afforded [HIM / HER].

	WHEREFORE PREMISES CONSIDERED, Defendant respectfully requests the sentencing hearing be expedited and rescheduled to [NEW SENTENCING DATE] at 8:30 a.m. or the earliest practicable date the court may choose.

						Respectfully submitted,

						BY: __________________________
						Name
						State Bar No. [BAR NUMBER]
						Address
						City, State, Zip
						Telephone 

CERTIFICATE OF SERVICE

	I, ______________ , certify that on the        day of [MONTH, YEAR], a copy of the foregoing was hand-delivered to the United States Attorney's office at _____________________________.
									
							                                                                               							Attorney for Defendant

UNITED STATES DISTRICT COURT
______________  DISTRICT OF TEXAS
______________  DIVISION

UNITED STATES OF AMERICA	                 §
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V.	                                                                 §	[NUMBER]
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[CLIENT]	                                                     §

ORDER

	On this the _______ day of [MONTH, YEAR], came to be heard Defendant’s Motion to Expedite Sentencing.  The Court is of the opinion that the motion should be GRANTED/DENIED.  
	Sentencing in this cause is set for ____________ on ___________________________.

						UNITED STATES DISTRICT JUDGE