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

Case 1:00-cr-00531-WYD

Document 1691

Filed 02/13/2006

Page 1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Criminal Action No. 00-CR-531-WYD UNITED STATES OF AMERICA, Plaintiff, v. WILLIAM CONCEPCION SABLAN, et al., Defendant. WILLIAM SABLAN'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE FINAL PHASE III MOTIONS

Defendant William Concepcion Sablan ("William"), by and through undersigned court-appointed counsel, moves for an extension of time to file other Phase III Motions to and including February 27, 2006.
1. On June 7, 2005 the Court issued a Scheduling Order which requires the defendant to file his Phase III Motions by February 13, 2006. 2. William Sablan's lawyers have been working diligently on the Phase III Motions and, indeed, are filing most (and perhaps all) of William's Phase III Motions today. 3. During the preparation of these Motions, defense counsel have been grappling with the voluminous discovery in this case. Defense counsel want to be certain that they have reviewed all discovery relating to all incidents mentioned by the government in its Amended Notice of Intent.

1

Case 1:00-cr-00531-WYD

Document 1691

Filed 02/13/2006

Page 2 of 3

3. Undersigned counsel believes he has adequately reviewed the discovery, however, in an abundance of caution, counsel wants to review the discovery one more time to be certain that all arguments relating to the Government's Amended Notice of Intent have been presented to the Court. 4. As noted above, undersigned counsel is not certain that William's lawyers will be filing any other Phase III Motions. If any other Phase III Motions were filed on or before February 27, 2006, it would not disrupt the schedule in this case.1 This is particularly true because the co-defendant Rudy Sablan has filed his Unopposed Motion for Extension of Time to File Phase III Motions. 5. AUSA Brenda Taylor does not oppose this request. WHEREFORE, the undersigned moves for an extension of time to and including February 27, 2006 in which to file any other Phase III Motions which are deemed appropriate after a final review of the discovery in this case. Dated: February 13, 2006 Respectfully submitted,

/s/ Patrick J. Burke
Patrick J. Burke Dean Neuwirth Burke & Neuwirth P.C. 1660 Wynkoop Street, Ste 810 Denver, CO 80202 (303) 825-3050 Nathan Chambers Chambers, Dansky & Mulvahill 1601 Blake Street, #300 Denver, CO 80202 (303) 825-2222
Government's Responses to Defendants Phase III Motions are due March 27, 2006, Replies are due April 21, 2006, and the Hearing on Phase III Motions begins May 15, 2006.
1

2

Case 1:00-cr-00531-WYD

Document 1691

Filed 02/13/2006

Page 3 of 3

Susan L. Foreman 1660 Wynkoop Street, Ste 810 Denver, Colorado 80202 (303) 825-3050 CERTIFICATE OF SERVICE

I hereby certify that on this 13th day of February, 2006 a true and correct copy of the above, WILLIAM SABLAN'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE FINAL PHASE III MOTIONS was filed with the Clerk of the Court using the CM/ECF system and was served via electronic mail to the following: Brenda Taylor ([email protected]) Phil Brimmer ([email protected]) Assistant U.S. Attorneys 1225 17th Street, Suite 700 Denver, Colorado 80202 Forrest Lewis ([email protected]) Attorney at Law 1600 Broadway, #1525 Denver, CO 80202 Attorney for Rudy Sablan Donald Knight ([email protected]) Attorney at Law 7852 S. Elati St., #201 Littleton, CO 80120 Attorney for Rudy Sablan /s/ Jennifer J. Feldman

3