Free Motion to Extend Time - District Court of Arizona - Arizona

Attorney for Defendant

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA

) ) Plaintiff, ) ) vs. ) ) ANDREW TAYLOR, ) ) Defendant. ) __________________________________________)

UNITED STATES OF AMERICA,

NO: CR04-0809-PHX-NVW

MOTION TO EXTEND TIME FOR SELF SURRENDER

Defendant, Andrew Taylor, by and through counsel undersigned, hereby respectfully requests that this Court extend the time for him to self surrender to not earlier than 10 A.M., April 7, 2006. Defendant is currently scheduled to surrender at noon on March 7, 2006. Defendant has filed a Motion for Release Conditions on Appeal in the 9th Circuit and undersigned counsel has filed a Motion to Withdraw. Defendant's counsel has also requested a stay of the self surrender date until the Court of Appeals can hear the motions. This motion is made so that the 9th Circuit can hear the motions and either grant or deny them. Defendant's counsel has also just been made aware of the defendant's request regarding the same matters by the defendant to this court and the court's ruling thereon. Undersigned counsel is filing this motion in accordance with that ruling.

Case 2:04-cr-00809-NVW

Document 135

Filed 03/06/2006

Page 1 of 2

Defendant's counsel has discussed this matter with AUSA John Lopez who indicates that he will probably object to the court allowing Mr. Taylor to remain free until the Court of Appeals can hear the motions. Based on the forgoing defendant respectfully requests that the court modify the self surrender order from March 7th, 2006 to a time to be set by the court not earlier than April 7th, 2006. RESPECTFULLY SUBMTTED this 6th day of March, 2006.

/s/ Cameron A. Morgan Cameron A. Morgan Attorney for Defendant

COPY of the foregoing sent electronically this 6th day of March, 2006, to: Honorable N. V. Wake U.S. District Court 401 W. Washington Street Phoenix, Arizona 85003 John Lopez John Tuchi Assistant United States Attorney 40 N. Central Avenue, Ste. 1200 Phoenix, Arizona 85004

BY:Dawn-Marie Kenney

2 Case 2:04-cr-00809-NVW Document 135 Filed 03/06/2006 Page 2 of 2