Free Motion for Extension of Time to File - District Court of Colorado - Colorado

Case 1:00-cr-00531-WYD

Document 1866

Filed 08/14/2006

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Criminal Case No. 00-cr-00531-WYD UNITED STATES OF AMERICA, Plaintiff, v. RUDY CABRERA SABLAN, et al. Defendant. ______________________________________________________________________________ UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE NOTICE OF EXPERT WITNESSES ______________________________________________________________________________ Rudy Sablan requests an additional 30 days, to and including September 14, 2006, in which to file his Notice of Expert Witnesses. In support of this motion, Defendant states as follows: 1. Defendant needs additional time to confer with some of the experts endorsed by

the government. Defendant also needs additional time to confer with potential defense experts. The additional time would allow Defendant to provide a more complete and accurate notice. 2. The government, through AUSA Brenda Taylor, has stated that it does not object

to the additional time requested herein. WHEREFORE, Defendant Rudy Sablan, requests an additional 30 days, to and including September 14, 2006, in which to file his Notice of Expert Witnesses.

Case 1:00-cr-00531-WYD

Document 1866

Filed 08/14/2006

Page 2 of 2

Respectfully submitted, s/ Forrest W. Lewis Forrest W. Lewis FORREST W. LEWIS, P.C. 1600 Broadway, Suite 1525 Denver, Colorado 80202 Telephone: (303) 830-2190 Facsimile: (303) 830-1466 E-mail: [email protected] Attorneys for Defendant Rudy Sablan

Donald R. Knight KNIGHT & MOSES, LLC 7852 S. Elati Street, Suite 201 Littleton, Colorado 80120 Telephone: (303) 797-1645 Facsimile: (303) 798-3872 E-mail: [email protected]

CERTIFICATE OF SERVICE I hereby certify that the foregoing UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE NOTICE OF EXPERT WITNESSES was electronically filed with the Clerk of the Court using the CM/ECF system on this 14th day of August, 2006, which will send notification of such filing to the to the following e-mail addresses: Brenda Taylor [email protected] Philip Brimmer [email protected] Patrick J. Burke [email protected] Dean Neuwirth [email protected] Nathan D. Chambers [email protected] Susan L. Foreman [email protected]

s/Polly Ashley