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

Case 1:00-cr-00531-WYD

Document 1717

Filed 03/22/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Criminal Case No. 00-cr-00531-WYD-01 UNITED STATES OF AMERICA, Plaintiff, v. 1. WILLIAM CONCEPCION SABLAN 2. RUDY CABRERA SABLAN, Defendants.

GOVERNMENT'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO RESPOND TO WILLIAM SABLAN'S MOTION TO STRIKE CONVICTION UNDER 18 U.S.C. § 924(h) FROM THE GOVERNMENT'S NOI AS A BASIS FOR THE ALLEGED STATUTORY AGGRAVATING FACTOR SET OUT IN 18 U.S.C. §3592 (c)(2) [Wm DP-27]

The United States of America, by William J. Leone, 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 Court extend the deadline for the government to respond to the above-referenced motion. The Government seeks an extension for the following reasons: 1. This motion was filed yesterday, March 21, 2006, with leave of Court, as a supplemental Phase III Death Penalty motion. Other Phase III motions were filed by William Sablan on February 13 and February 27, 2006. 1

Case 1:00-cr-00531-WYD

Document 1717

Filed 03/22/2006

Page 2 of 3

2. The government's deadline for responding to all Phase III motions filed by both defendants is March 27, 2006. 3. The government requires additional time to respond to this motion and seeks an extension until April 10, 2006. 4. The defendant indicated in his motion that he would have no objection to a government request for additional time, and no prejudice will result from the delay. WHEREFORE, the government respectfully requests that the Court grant an extension until April 10, 2006 for the filing of the government's response to the abovereferenced motion. Respectfully submitted this 22 nd day of March, 2006. WILLIAM J. LEONE 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) 454-0403 E-mail address: [email protected] Attorney for Government

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Case 1:00-cr-00531-WYD

Document 1717

Filed 03/22/2006

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on this 22 nd day of March, 2006, I electronically filed the foregoing GOVERNMENT'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO RESPOND TO WILLIAM SABLAN'S MOTION TO STRIKE CONVICTION UNDER 18 U.S.C. § 924(h) FROM THE GOVERNMENT'S NOI AS A BASIS FOR THE ALLEGED STATUTORY AGGRAVATING FACTOR SET OUT IN 18 U.S.C. §3592 (c)(2) [Wm DP-27] with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses: Attorneys for William Sablan Patrick J. Burke [email protected] Attorneys for Rudy Sablan Donald R. Knight [email protected] Forrest W. Lewis [email protected]

Nathan Dale Chambers [email protected] [email protected]

Susan Lynn Foreman [email protected]

Dean Steven Neuwirth [email protected]

s/ Donna Summers DONNA SUMMERS Legal Assistant U.S. Attorney's Office 1225 17th Street, Suite 700 Denver, CO 80202 Phone (303) 454-0100 Fax (303) 454-0406 E-mail address [email protected]

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