Free Motion for Extension of Time - District Court of Arizona - Arizona

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MARK PAIGE 45 West Jefferson Luhrs Tower - Suite #806 Phoenix, AZ 85003-2317 (602) 254-5457 State Bar #020902 [email protected] Attorney for Defendant

UNITED STATES DISTRICT COURT 7 8 9 10 11 12 13 14 The Petitioner, Jaime Flores, hereby moves the court for an Order granting an additional 15 extension of time to March 13, 2006 to file any objections to the Report and Recommendation 16 of the Magistrate Judge in the above-entitled matter. This motion is made for the following 17 reasons: 18 1. The Report and Recommendation was filed on or about December 12, 2005. Counsel 19 for the Petitioner was unable to review the Report and Recommendation due to the urgent 20 press of other matters. Counsel has been inundated with other matters including trial in 21 Prescott and preparation of motions and replies in a large, multi-defendant matter and 22 preparation for various hearings and trial related matters in that same case (CR-03-116723 PHX-DGC). 24 2. Counsel has sent a copy of the Report and Recommendation to the Petitioner at the 25 Arizona State Prison Complex in Tucson, Arizona. Counsel has not had opportunity to 26 discuss the matter with the client as yet. Time is needed for counsel to speak with the 27 client, provide materials he may request, complete any needed research and file the 28 DISTRICT OF ARIZONA _______________________________________ ) Jaime Flores, ) No.: CV-02-2065-PHX-DGC(MS) ) Petitioner, ) ) MOTION TO EXTEND TIME v. ) FOR FILING OBJECTIONS TO ) MAGISTRATE'S REPORT AND Terry L. Stewart, et al., ) RECOMMENDATION ) Respondents. ) (Second Request) _______________________________________)

Case 2:02-cv-02065-DGC

Document 44

Filed 02/02/2006

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appropriate objections. 3. In addition, counsel is in need of additional time for his own review of the Report and Recommendation in order to prepare any necessary objections.

Counsel for the Respondents, Robert Walsh, has no objection to this request. WHEREFORE, counsel for petitioner, Jaime Flores, respectfully requests the time to file a objections to the Report and Recommendation be continued to March 13, 2006.

Respectfully submitted this 2nd day of February, 2006.

S/ Mark A. Paige MARK PAIGE Attorney for Defendant Copy of the foregoing was mailed/delivered this 2nd day of February 2005 to: Robert Walsh Assistant Attorney General Criminal Appeals Section 1275 W. Washington St. Phoenix, AZ 85007-2997

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s/ Mark A. Paige Mark A. Paige

Case 2:02-cv-02065-DGC

Document 44

Filed 02/02/2006

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