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

Case 1:00-cr-00481-WYD

Document 1669

Filed 02/04/2006

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Criminal Case No. 00-CR-481-D UNITED STATES OF AMERICA, Plaintiff, v. ROD SCHULTZ, Defendant.

MOTION FOR EXTENSION OF TIME TO FILE REPLY

COMES NOW Rod Schultz, by counsel, moves for an extension of time to reply to the government'pleading, and in support thereof states as follows: s 1. On January 20, 2006 the government files a response to defendant'motion s seeking a new trial. Any reply by the defendant is due on or before February 4, 2006; 2. Rod Schultz requests an extra three days to file his reply, until February 7, 2006; 3. In support of this request the defense states the responsive pleading by the government (16 pages) was more than twice the length of the motion, contained many separate arguments and references to the record, and many parts of the extremely long record must be searched to adequately reply to the government' s argument;

Case 1:00-cr-00481-WYD

Document 1669

Filed 02/04/2006

Page 2 of 2

4. The defense is unable to contact the government concerning this request. It submits the government will not be unduly prejudiced by a three day extension. WHEREFORE, for the above reasons the defense requests an extension of time, until February 7, 2006 to make reply to the government'pleading. s Respectfully submitted,

s/ Neil MacFarlane_____________ Neil MacFarlane 9975 Wadsworth Pkwy, K2-433 Westminster, CO. 80021 Attorney for Rod Schultz (303) 893-2544 FAX (303) 420-0831 neil_macfarlane_law@yahoo Certificate of Service I hereby certify that on February 4, 2006 I electronically filed the foregoing pleading with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses: Robert Mydans [email protected]

s/ Neil MacFarlane____________