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 a 30 day extension to file a response for the reason that undersigned counsel has been involved 19 in extensive trial preparation in United States v. Joshua Trotter, CR 05-1135-PHX-PGR. That 20 matter settled unexpectedly just prior to trial. Additional time is needed to review the underlying 21 record, research the issues and respond to the six separate claims made by the defendant. 22 Counsel will also need to meet with defendant's former counsel after former counsel has 23 reviewed his files in order to address the ineffective assistance claim. 24 Excludable delay under 18 U.S.C. 3161(h) will not occur as a result of this motion and order 25 based thereon. 26 27 28

Case 2:02-cr-00155-JAT

Document 315

Filed 09/26/2006

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Respectfully submitted this 26th day of September, 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 September 26, 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 315

Filed 09/26/2006

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