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

Case 1:01-cr-00214-WYD

Document 3594

Filed 05/16/2008

Page 1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Criminal Case NO. 01-CR-214-WYD UNITED STATES OF AMERICA, Plaintiff, v. GEORGE MURRAY, Defendant. ______________________________________________________________________________ MOTION FOR EXTENSION OF TIME TO SUBMIT MOTION FOR RECONSIDERATION OF SENTENCE ______________________________________________________________________________ Defendant GEORGE MURRAY, by through his attorney, Wade Eldridge, PC, requests that this Honorable Court allow him until Monday, June 2, 2008, in which to file a motion for reconsideration of sentence, and AS GROUNDS THEREFORE, states as follows: 1. The undersigned has been appointed to represent Defendant GEORGE MURRAY to represent him in connection with a motion seeking reconsideration of his sentence in light of recent Supreme Court decisions. It may be that the sentence of Defendant GEORGE MURRAY was a "minimum mandatory" sentence that is unaffected by those decisions. However, more time is required to research those issues. 2. The undersigned in completing a trial management order, due today, and is preparing for an arbitration in a brain injury case on Tuesday.

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Case 1:01-cr-00214-WYD

Document 3594

Filed 05/16/2008

Page 2 of 3

3. The undersigned has conferred with A.U.S.A. Guy Till concerning this motion, and the Government has no objection.

WHEREFORE, Defendant GEORGE MURRAY respectfully requests that he be granted an extension of time, up to and including June 2, 2008, in which to file a motion for reconsideration of sentence. Defendant also requests such other and further relief as may be just and proper. Dated May 16, 2008

Respectfully submitted, WADE H. ELDRIDGE, PC _S/ Wade H. Eldridge Wade H. Eldridge 1471 Stuart St. Denver Colorado 80204 (303) 861-4222 Attorney Defendant GEORGE MURRAY

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Case 1:01-cr-00214-WYD

Document 3594

Filed 05/16/2008

Page 3 of 3

CERTIFICATE OF SERVICE (CM/ECF)

I hereby certify that on May 16, 2008, I electronically filed the foregoing MOTION FOR EXTENSION OF TIME TO SUBMIT MOTION FOR RECONSIDERATION OF SENTENCE with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following counsel:

Guy Till Assistant United States Attorney [email protected] And I hereby certify that I have mailed or served the document or paper of the following nonCM/ECF participants in the manner indicated: None S/Michelle M. Counce Michelle M. Counce Paralegal Wade H. Eldridge, P.C. 1471 Stuart Street Denver Colorado 80204 (303) 861-4222 [email protected]

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