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

Case 1:04-cr-00103-REB

Document 1312

Filed 07/05/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Case Number: 04-cr-000103-REB

UNITED STATES OF AMERICA, Plaintiff, v.

4. CHARLES LEWIS Defendant. MOTION FOR EXTENSION OF TIME TO FILE SENTENCING STATEMENT ________________________________________________________________________

Comes now the Defendant, Charles Franklin Lewis, through his undersigned counsel, Ronald Gainor, who files this, Motion for Extension of Time to File Sentencing Statement and, in support, would allege the following: 1. Undersigned counsel needs more time to review relevant materials and confer with

his client prior to filing a sentencing statement in this case. He would request that he be granted an extension of time up to and including July 15, 2007 to submit said filing to the U. S. Probation Office. 2. The United States was previously granted a 17 day extension of time to file its

statement in this matter.

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Case 1:04-cr-00103-REB

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3.

Undersigned counsel has been unable to ascertain United States Probation Officer

Tom Destito's position on this motion because he is out of town and unavailable until July 9, 2007. Wherefore, based on the above and foregoing, undersigned counsel for the Defendant, Charles Franklin Lewis, respectfully requests that this Honorable Court grant an extension of time to file a sentencing statement in this matter. Dated this 5th day of July, 2007

Respectfully submitted, s/ Ronald Gainor RONALD GAINOR 6414 Fairways Drive Longmont, CO 80503 (303) 448-9646(phone) (303) 447-0930 (Facsimile) [email protected] Attorney for Charles Lewis

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Case 1:04-cr-00103-REB

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CERTIFICATE OF SERVICE (CM/ECF)

I hereby certify that I have electronically filed the foregoing on this 5th day of July, 2007 with the Clerk of the Court using the ECF system which will send notification of such filing to the following e-mail addresses:

Matthew Kirsch [email protected] Wyatt B. Angelo [email protected] Peter Bornstein [email protected] Thomas Hammond [email protected] Thomas Goodreid [email protected] Daniel Smith [email protected] Declan O'Donnell [email protected]

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Mitchell Baker [email protected] Richard Kornfeld [email protected] Richard Stuckey [email protected]

s/ Ronald Gainor

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