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

Case 1:04-cr-00103-REB

Document 1311

Filed 07/05/2007

Page 1 of 3

IN THE UNITED STATES DISTRICT COURT F0R THE DISTRICT OF COLORADO Criminal Case No. 04-cr-00103-REB UNITED STATES OF AMERICA, Plaintiff, v. 2. GEORGE ALAN WEED Defendant. ________________________________________________________________________ DEFENDANT WEED'S MOTION FOR EXTENSION OF TIME TO FILE SENTENCING STATEMENT ________________________________________________________________________ Defendant George Alan Weed, through counsel, requests an extension of time, up to and including 20 July 2007, to submit to the U.S. Probation Office a sentencing statement under U.S. District Court (Colorado) General Order 2002-3(B). The Government, otherwise obligated to file its sentencing statement under said Order, by 5 June 2007, obtained an extension of time to file its statement on 22 June 2007. Weed's undersigned counsel was out of town on vacation and on another CJAappointed case, from 22 June 2007 until 4 July 2007. As a result, the undersigned did not have an opportunity to begin reviewing the Government's 37 page sentencing statement (not to mention the approximately two inches thick set of accompanying spreadsheets) until today, one day before a response presently is due under the time limits established by the aforesaid Order. Given the Government's contention in its statement that Mr. Weed should be sentenced to a minimum of 235 months, Mr. Weed not surprisingly wishes to file a

Case 1:04-cr-00103-REB

Document 1311

Filed 07/05/2007

Page 2 of 3

detailed sentencing statement of his own, one which fairly responds to the multiple factual and legal assertions set forth by the Government in its statement. Mr. Weed therefore requests that his counsel have an adequate opportunity to prepare his sentencing statement. The undersigned discussed this request for extra time with Susan Heckman, the U.S. Probation Officer assigned to prepare the presentence report on Mr. Weed. Ms. Heckman advised that, given the exigencies of her schedule, she has no objection to the requested extension of time. Mr. Weed accordingly requests that this Motion be granted. Dated this 5th day of July, 2007. Respectfully submitted,

s/Thomas E. Goodreid Thomas E. Goodreid 1801 Broadway, Suite 1100 Denver, CO 80202 Telephone: (303) 292-0110 Fax: (303) 292-0522 E-Mail: [email protected] Attorney for Defendant George Alan Weed

2

Case 1:04-cr-00103-REB

Document 1311

Filed 07/05/2007

Page 3 of 3

CERTIFICATE OF SERVICE I certify that on 5 July 2007, I electronically filed the foregoing DEFENDANT WEED'S MOTION FOR EXTENSION OF TIME TO FILE SENTENCING STATEMENT with the Clerk of Court using the CM/ECF system, which will send notification of such filing to the following e-mail addresses: [email protected] (Thomas J. Hammond) [email protected] (Richard Stuckey) [email protected] (Daniel T. Smith) [email protected] (Declan Joseph O'Donnell) [email protected] Mitchell Baker [email protected] (Peter R. Bornstein) [email protected] (Ronald Gainor) [email protected] (Mathew T. Kirsch) [email protected] (Wyatt B. Angelo) [email protected] Richard Kornfeld

s/Thomas E. Goodreid Thomas E. Goodreid 1801 Broadway, Suite 1100 Denver, CO 80202 Telephone: (303) 292-0110 Fax: (303) 292-0522 E-Mail: [email protected] Attorney for Defendant George Alan Weed

3