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

Case 1:04-cr-00103-REB

Document 1316

Filed 07/06/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Case No. 04-cr-00103-REB UNITED STATES OF AMERICA, Plaintiff, v. 1. NORMAN SCHMIDT,

Defendant. _________________________________________________________________ DEFENDANT NORMAN SCHMIDT'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE RESPONSE TO GOVERNMENT'S SENTENCING STATEMENT _________________________________________________________________ Defendant, Norman Schmidt, by and through his attorneys, Peter R. Bornstein and Thomas J. Hammond, moves for an extension of time in which to file his response to the government's sentencing statement. As grounds, Mr. Schmidt states the following: 1. As the Court is aware, the sentencing statement is lengthy and is

accompanied by a thick packet of supporting information that must be reviewed in order to respond accurately. 2. Two co-defendants, Mr. Weed and Mr. Lewis, have asked for and been

granted an extension to file their responses to July 20, 2007. 3. Undersigned counsel has contacted Assistant United States Attorneys

Wyatt Angelo and Matthew Kirsch, and is authorized to represent that they do not oppose this motion. 1

Case 1:04-cr-00103-REB

Document 1316

Filed 07/06/2007

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WHEREFORE, Mr. Schmidt moves for an extension of time to file his response to the government's sentencing statement in this case, specifically to July 20, 2007.

Respectfully submitted,

s/ Thomas J. Hammond Thomas J. Hammond Thomas J. Hammond, P.C. 1544 Race Street Denver, Colorado 80206 telephone: (303)321-7902 fax: (303)329-5871 e-mail: [email protected] Attorney for Norman Schmidt s/ Peter R. Bornstein Peter R. Bornstein The Law Offices of Peter R. Bornstein 1600 Broadway, Suite 2300 Denver, Colorado 80202 (303)861-2500 Fax: (303)861-0420 E-mail: [email protected] Attorney for Norman Schmidt

CERTIFICATE OF SERVICE (CM/ECF) I hereby certify that on July 6, 2007, I electronically filed the foregoing DEFENDANT NORMAN SCHMIDT'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE RESPONSE TO GOVERNMENT'S SENTENCING STATEMENT with the Clerk of the Court using the CM/ECF filing system which will send notification of such filing to the following e-mail addresses:

Wyatt Angelo, Esq. [email protected] Matthew Kirsch, Esq. [email protected] 2

Case 1:04-cr-00103-REB

Document 1316

Filed 07/06/2007

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Peter R. Bornstein, Esq. [email protected] Ronald Gainor, Esq. [email protected] Thomas E. Goodreid, Esq. [email protected] Richard Stuckey, Esq. [email protected] Declan O'Donnell, Esq. [email protected]

s/Thomas J. Hammond Thomas J. Hammond

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