Free Motion for Miscellaneous Relief - District Court of Colorado - Colorado

Case 1:01-cr-00214-WYD

Document 3555

Filed 03/10/2008

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Criminal Case No. 01-cr-00214-WYD UNITED STATES OF AMERICA, Plaintiff,

v.

19. SAMMY LEE WOODS Defendant. ______________________________________________________________________________ MOTION TO EXTEND RESPONSE DATE FOR DEFENDANT'S POSITION REGARDING ELIGIBILITY OF SENTENCE REDUCTION REQUEST ______________________________________________________________________________ Comes now CJA counsel for Defendant Sammy Lee Woods, who files this Motion to Extend Response Date for Defendant's Position Regarding Eligibility of Sentence Reduction Request and, in support, would allege the following; 1. On February 27, 2008, undersigned counsel was appointed to represent the defendant in his

attempt to secure a sentence reduction pursuant to 18 U.S.C Section 3582(c)(2). 2. Pursuant to this appointment, counsel was ordered to file a notice with the Court by March 10,

2008 indicating whether or not the defendant is eligible for such relief. 3. As of this date, undersigned counsel has been unable to confer with his client, who is currently

incarcerated in the Memphis Federal Correctional Institute.

Case 1:01-cr-00214-WYD

Document 3555

Filed 03/10/2008

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4.

Based on these circumstances, counsel requests that this Honorable Court extend the current

response date in this matter for a period of three (3) weeks. 5. Undersigned counsel has left a message for Assistant United States Attorney Guy Till seeking

his position regarding the relief requested in this motion. As of this date, however, counsel has not received the government's position on this request. WHEREFORE based on the above and foregoing, undersigned counsel for Defendant Sammy Lee Woods moves this Honorable Court to extend the response date in this matter for a period of three (3) weeks Dated this 10th day of March, 2008 Respectfully submitted, s/ Ronald Gainor RONALD GAINOR 6414 Fairways Drive Longmont, CO 80503 (303) 448-9646 (303) 447-0930 (fax) [email protected]

Case 1:01-cr-00214-WYD

Document 3555

Filed 03/10/2008

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CERTIFICATE OF SERVICE I hereby certify that I have electronically filed this Notice on this 10th day of March, 2008 with the Clerk of the United States District Court using the ECF system which will send notification of this filing to the following party: Guy Till [email protected]

I also hereby certify that a copy of said motion was mailed to the following non-CM/ECF participant at the following location: Mr. Sammy Lee Woods Federal Register Number 30425-013 Federal Correctional Unit: Memphis Beale B Unit Memphis, TN 38138-0550 MEMPHIS FEDERAL CORRECTIONAL INSTITUTE Sammy Lee Woods Reg # 30425-013 Beale B Unit Memphis, TN 38138-0550

s/ Ronald Gainor RONALD GAINOR 6414 Fairways Drive Longmont, CO. 80503 (303) 448-9646 (303) 447-0930 (fax) [email protected]