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

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G EORGE F. K LINK
45 West Jefferson Luhrs Tower - Suite #810 Phoenix, AZ 85003-2328 (602) 253-3889 State Bar #004057 Attorney for Defendant IN THE UNITED STATES DISTRICT COURT

6 DISTRICT OF ARIZONA 7 ____________________________________ 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 By: /s/ George F. Klink Attorney for Defendant United States of America, ) ) ) Plaintiff, ) ) v. ) ) Joseph Cayer, ) ) Defendant. ) ____________________________________) No. CR03-01164-010-PHX-PGR MOTION FOR EXTENSION OF TIME TO FILE OBJECTIONS TO PRESENTENCE REPORT

Defendant, Joseph Cayer, by and through counsel undersigned, respectfully requests an extension of time until July 24, 2006 in which to file objections to the Presentence Report for the following reason: Due to undersigned counsel's recent Federal and State court calendars, counsel has not had the opportunity in which to properly review the report. The Government, by Assistant United States Attorney, Tim Duax, does not oppose this extension. This request is made in order to afford Defendant the effective assistance of counsel mandated by the constitution. This motion is brought in good faith for the reasons stated and not for the purpose of delay. EXCLUDABLE DELAY pursuant to 18 U.S.C. §3161(h)(8)(A) and (h)(I)(F) may result from this motion and any order entered. Respectfully submitted this 20th day of July, 2006.

Case 2:03-cr-01164-PGR

Document 452

Filed 07/20/2006

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1 CERTIFICATE OF SERVICE 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 By: /s/ Susan L. West 17 18 19 20 21 22 23 24 25 26 27 28 Beth Stewart United States Probation Officer 401 West Washington Street Suite 160, Space 7 Phoenix, AZ 85003 facsimile (602) 322-7409 I hereby certify that on July 20, 2006, I electronically transmitted the attached document to the Clerk's Office using the ECF system for filing and transmittal of a Notice of Electronic Filing to the following ECF registrants: Hon. Paul G. Rosenblatt United States District Court 401 West Washington Street Phoenix, AZ 85003 [email protected] Timothy T. Duax, Esq. [email protected] Assistant United States Attorney Copy of the foregoing faxed/mailed this 20th day of July, 2006 to:

2 Case 2:03-cr-01164-PGR Document 452 Filed 07/20/2006 Page 2 of 2