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

1 TIMOTHY C. HOLTZEN 2 3 4 5 6 7 8 United States of America, 9 10
v. Plaintiff,
Attorney at Law 245 W. Roosevelt St. Phoenix, Arizona 85003 State Bar No. 004723 (602) 799-6336 (602) 368-9140 fax Attorney for Defendant

UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA ) ) ) ) ) ) ) ) ) ) No. CR 03-0974-PHX-DGC MOTION TO EXTEND TIME TO FILE REPLY

11 Neil Rusty Bond, 12 Defendant. 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

The defendant, through undersigned counsel, moves this Court to Extend the Time to File the Reply to the Government's Response to Defendant's Memorandum Re: New Trial Based on Newly Discovered Evidence for one (1) business day to and including February 21, 2006. The reply is presently due February 17, 2006. Sentencing is set for March 1, 2006. Defense counsel was out of state from February 7, 2006, through February 10, 2006. The government's response was filed February 9, 2006. Defense Counsel has recently received additional materials to review and seeks further information before filing the reply. The Assistant U.S. Attorney assigned to this case, Michelle Hamilton-Burns, has no objection to this request. RESPECTFULLY SUBMITTED this 17 th day of February 2006.

\s Timothy C. Holtzen Timothy C. Holtzen Attorney for Defendant

Case 2:03-cr-00974-DGC

Document 172

Filed 02/17/2006

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Copy of the foregoing served by ECF filing this 17th day of February 2006 to: Michelle Hamilton-Burns Joscelyn N. Funnié Assistant U.S. Attorneys Two Renaissance Square 40 N. Central Avenue, Suite 1200 Phoenix, Arizona 85004-4408 Copy of the foregoing mailed this 17th day of February 2006 to: Neil Rusty Bond Defendant Jon Evanko U.S. Probation Office

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Case 2:03-cr-00974-DGC

Document 172

Filed 02/17/2006

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