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

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

PAUL K. CHARLTON United States Attorney District of Arizona KEITH E. VERCAUTEREN Assistant U.S. Attorney Two Renaissance Square 40 North Central Avenue, Suite 1200 Phoenix, Arizona 85004-4408 Arizona State Bar No. 013439 [email protected] Telephone (602) 514-7500

UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA United States of America, Plaintiff, v. Carolyn Ann Reed, Defendant. No. CR-03-0421-PHX-SMM No. CV-06-2030-PHX-SMM (HCE) UNITED STATES' MOTION TO EXTEND THE TIME TO FILE A RESPONSE TO DEFENDANT'S MOTION TO VACATE, SET ASIDE OR CORRECT SENTENCE PURSUANT TO 28 U.S.C. § 2255

The United States, by and through undersigned counsel, respectfully moves this Court for an extension of time to file a response to defendant's Motion to Vacate, Set Aside or Correct Sentence Pursuant to 28 U.S.C. § 2255. The United States requests an extension of time to file the response from January 3, 2007, to February 7, 2007. The United States requests an extension because undersigned counsel would like to refer to the transcripts of the change of plea and sentencing proceedings. The transcripts of those two proceedings were ordered on November 6, 2006, and as of this writing have not been received. Counsel for the United States would like to have additional time to properly complete the response after the transcripts are reviewed. Excludable delay under 18 U.S.C. § 3161(h)(8)(A) may occur as a result of this motion or from an order based thereon. Respectfully submitted this 19th day of December, 2006. PAUL K. CHARLTON United States Attorney District of Arizona s/ Keith Vercauteren KEITH E. VERCAUTEREN Assistant United States Attorney

Case 2:03-cr-00421-SMM

Document 589

Filed 12/19/2006

Page 1 of 2

1 2 3 4 5

CERTIFICATE OF SERVICE I hereby certify that on December 19, 2006, I electronically transmitted the attached document to the Clerk's Office using the CM/ECF System for filing and transmittal of a Notice of Electronic Filing to the following CM/ECF registrant:

Michael L. Freeman 320 E. Virginia, Suite 200 6 Phoenix, Arizona 85004-1225 Attorney for Carolyn Reed
7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

s/Keith Vercauteren Keith Vercauteren Assistant U.S. Attorney

Case 2:03-cr-00421-SMM

Document 589

Filed 12/19/2006

Page 2 of 2