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

Case 1:00-cr-00531-WYD

Document 2688

Filed 12/27/2007

Page 1 of 2

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. RUDY CABRERA SABLAN, Defendant. ______________________________________________________________________________ UNOPPOSED MOTION FOR EXTENSION OF TIME TO DISCLOSE EXPERT WITNESSES ______________________________________________________________________________ Rudy Sablan, by and through counsel, requests an additional four days, to and including January 4, 2008, in which to disclose expert witnesses. In support of his request for this extension of time, Mr. Sablan states as follows: 1. The scheduling order requires disclosure of expert witnesses on or before

December 31, 2007. Because of the holidays, defense counsel does not have access to many of Defendant's expert witnesses to obtain the final summaries of their anticipated testimony. 2. The government, through AUSA Brenda Taylor, does not oppose this motion.

WHEREFORE, Rudy Sablan requests an additional four days, to and including January 4, 2008, in which to disclose expert witnesses under F.R.CRIM .P. 16(b)(1)(c).

Case 1:00-cr-00531-WYD

Document 2688

Filed 12/27/2007

Page 2 of 2

Respectfully submitted, s/ Forrest W. Lewis 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] Donald R. Knight KNIGHT & MOSES, LLC 7852 S. Elati Street, Suite 201 Littleton, Colorado 80120 Telephone: (303) 797-1645 Facsimile: (303) 730-0858 E-mail: [email protected] Attorneys for Defendant Rudy Sablan CERTIFICATE OF SERVICE I hereby certify that the foregoing UNOPPOSED MOTION FOR EXTENSION OF TIME TO DISCLOSE EXPERT WITNESSES was electronically filed with the Clerk of the Court using the CM/ECF system on this 27th day of December, 2008, which will send notification of such filing to the to the following e-mail addresses: Brenda Taylor [email protected] Philip Brimmer [email protected]

s/Polly Ashley