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

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PAUL K. CHARLTON United States Attorney District of Arizona DAVID A. PIMSNER Assistant U.S. Attorney Arizona State Bar No. 007480 Two Renaissance Square 40 North Central Avenue, Suite 1200 Phoenix, Arizona 85004 Telephone: (602) 514-7500 [email protected]

UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA United States of America CR-02-0155-PHX-JAT Plaintiff, v. Steve Cordell Dobson, Defendant/Movant. GOVERNMENT'S MOTION FOR AN EXTENSION OF TIME TO FILE RESPONSE TO MOTION TO VACATE, SET ASIDE, OR CORRECT SENTENCE CV-06-1539-PHX-JAT (MEA)

The United States of America, by and through undersigned counsel, respectfully requests

16 an extension of time in which to file a response to the Motion to Vacate, Set Aside, or Correct 17 Sentence filed by the defendant/movant pursuant to 18 U.S.C. § 2255. The government requests 18 an extension until December 5, 2006, to file a response for the reason that undersigned counsel 19 needs additional time to obtain an affidavit from the defendant's original trial counsel to refute 20 the defendant's allegations. Additionally, undersigned counsel, has had some difficulty in 21 reaching appellate counsel, who is also alleged to have been ineffective, to obtain an affidavit 22 to refute the defendant's allegations. Because the underlying record is extensive and that there 23 are numerous issues alleged, additional time is needed to prepare the affidavits and to adequately 24 respond to the defendant's claims. Excludable delay under 18 U.S.C. 3161(h) will not occur as a result of this motion and order 25 26 based thereon. 27 28

Case 2:02-cr-00155-JAT

Document 326

Filed 11/22/2006

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Respectfully submitted this 22nd day of November, 2006. PAUL K. CHARLTON United States Attorney District of Arizona s/ David A. Pimsner DAVID A. PIMSNER Assistant U.S. Attorney

I hereby certify that on November 22, 2006, I served the attached document by U.S. Postal mail on the following, who is not a registered participant of the CM/ECF system: Steve Cordell Dobson #17338-075 FCI- Memphis P.O. Box 34550 Memphis, Tennessee 38184

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Case 2:02-cr-00155-JAT

Document 326

Filed 11/22/2006

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