Free Motion for Extension of Time to File - District Court of Colorado - Colorado

Case 1:00-cr-00531-WYD

Document 2704

Filed 01/16/2008

Page 1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Criminal Case No.00-cr-00531-WYD-02 UNITED STATES OF AMERICA, Plaintiff, v. 2. RUDY CABRERA SABLAN, Defendant.

GOVERNMENT'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO PROVIDE NOTICE OF REBUTTAL EXPERT WITNESSES

The United States of America, by Troy A. Eid, United States Attorney for the District of Colorado, and through Brenda K. Taylor and Philip A. Brimmer, Assistant U.S. Attorneys, respectfully requests that the deadline for providing notice of rebuttal expert witnesses be extended by one week from January 22, 2008 until January 29, 2008. The reasons for this request are as follows: 1. The parties have provided notice of their expert witnesses, the government on December 31, 2007, and the Defendant, upon the granting of an unopposed motion for extension, on January 4, 2008. 2. The defendant has given notice that he intends to call eight experts, possibly seven during his case in chief. 3. The government has requested some clarification from defense counsel

Case 1:00-cr-00531-WYD

Document 2704

Filed 01/16/2008

Page 2 of 3

regarding the areas of the anticipated expert testimony and the bases and reasons for the testimony. This additional information is necessary in order to identify possible government rebuttal experts and provide adequate notice of their testimony. 4. We are asking for a brief extension, from January 22 until January 29, 2008, in order to accomplish this. 5. Counsel for the government has conferred with Forrest Lewis, counsel for defendant Rudy Sablan, and Mr. Lewis has no objection to the government's request.

Respectfully submitted this 16th day of January, 2008, TROY A. EID United States Attorney

BY: s/ Brenda K. Taylor BRENDA K. TAYLOR Assistant U.S. Attorney U.S. Attorney's Office 1225 17 th Street, Suite 700 Denver, Colorado 80202 Telephone (303)454-0100 FAX: (303) 454-0406 E-mail address: [email protected] Attorney for Government

BY: s/ Philip A. Brimmer PHILIP A. BRIMMER Assistant U.S. Attorney U.S. Attorney's Office 1225 17 th Street, Suite 700 Denver, Colorado 80202 Telephone (303)454-0100 FAX: (303) 454-0406 E-mail address: [email protected] Attorney for Government

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Case 1:00-cr-00531-WYD

Document 2704

Filed 01/16/2008

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on this 16th day of January, 2008, I electronically filed the foregoing GOVERNMENT'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO PROVIDE NOTICE OF REBUTTAL EXPERT WITNESSES with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses: Forrest W. Lewis FORREST W. LEWIS, P.C. 1600 Broadway, Suite 1525 Denver, Colorado 80202 Telephone: (303) 830-2190 Facsimile: (303) 830-1466 E-mail: [email protected] Attorney for Defendant Rudy Sablan Donald R. Knight KNIGHT & MOSES, LLC 7852 S. Elati Street, Suite 201 Littleton, Colorado 80120 Telephone: (303) 797-1645 Facsimile: (303) 730-0858 Email: [email protected] Attorney for Defendant Rudy Sablan

s/ Veronica Ortiz VERONICA ORTIZ Legal Assistant U.S. Attorney's Office 1225 17th Street, Suite 700 Denver, CO 80202 Phone: (303) 454-0335 Fax: (303) 454-0406 E-mail address: [email protected]

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