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

Case 1:00-cr-00531-WYD

Document 1678

Filed 02/10/2006

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Criminal Case No. 00-cr-00531-WYD UNITED STATES OF AMERICA, Plaintiff, v. RUDY CABRERA SABLAN, et al. Defendant. ______________________________________________________________________________ UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE PHASE III MOTIONS ______________________________________________________________________________ Rudy Sablan, by and through counsel, requests an additional eight days, to and including February 21, 2006, in which to file Phase III motions in this matter. As grounds, Defendant states: 1. Counsel has been in trial this week in Jefferson County District Court and needs

additional time to complete the Phase III motions. 2. No previous extensions have been requested. AUSA Brenda Taylor has

authorized counsel to state that the government does not object to the extension of time requested herein. WHEREFORE, Defendant requests an additional eight days, to and including February 21, 2006, in which to file Phase III motions.

Case 1:00-cr-00531-WYD

Document 1678

Filed 02/10/2006

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) 798-3872 E-mail: [email protected] CERTIFICATE OF SERVICE I hereby certify that the foregoing UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE PHASE III MOTIONS was electronically filed with the Clerk of the Court using the CM/ECF system on this 10th day of February, 2006, which will send notification of such filing to the to the following e-mail addresses: Brenda Taylor [email protected] Philip Brimmer [email protected] Michael Hegarty [email protected] Patrick J. Burke [email protected] Dean Neuwirth [email protected] Nathan D. Chambers [email protected] s/Polly Ashley Susan L. Foreman [email protected]