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

Case 1:01-cr-00214-WYD

Document 3549

Filed 02/27/2008

Page 1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Criminal Case No. 01-cr-00214-WYD UNITED STATES OF AMERICA, Plaintiff, v. 29. TOMMY JONES, Defendant.

GOVERNMENT'S MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO ISSUE OF POSSIBLE REDUCTION OF SENTENCE UNDER TITLE 18 U.S.C. SECTION 3582 (DOC 3541)

The United States of America, by District of Colorado United States Attorney Troy A. Eid, through Assistant U.S. Attorney (AUSA) Guy Till (Government), hereby respectfully aks the Court for an enlargement of time, through and including March 18, 2008, within which to file a response to the issue of the defendant's possible relief pursuant to Title 18 U.S.C. § 3582, as directed in the Minute Order dated February 11, 2008. (DOC 3541). Said Minute Order directs the Government to respond no later than March 3, 2008. In order to advise the Court of the Government's position as to a possible sentence adjustment for Tommy Jones pursuant to Title 18 U.S.C. § 3582, the Government needs to locate and review the defendant's presentence report. The Government appreciates the initiative of counsel for the Defendant, Stephen C. Peters, Esq., who has called the Government and made a proposal which may eventually prove 1

Case 1:01-cr-00214-WYD

Document 3549

Filed 02/27/2008

Page 2 of 3

acceptable to the Government. However, in order to gather the necessary presentence report documents, which may be archived at this point, and review those documents in light of the applicable law, the Government respectfully asks the Court for an enlargement of time of approximately two weeks, permitting the parties to inform the Court, as directed by said Minute Order, no later than March 18, 2008. Respectfully submitted this 27th day of February 2008. TROY A. END UNITED STATES ATTORNEY

BY: s/ Guy Till GUY TILL Assistant United States Attorney United States Attorney's Office District of Colorado 1225 17th Street, Suite 700 Denver, CO 80202 (303) 454-0100 [email protected]

2

Case 1:01-cr-00214-WYD

Document 3549

Filed 02/27/2008

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on this 27th day of February, 2008, I electronically filed the foregoing GOVERNMENT'S MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO ISSUE OF POSSIBLE REDUCTION OF SENTENCE UNDER TITLE 18 U.S.C. SECTION 3582 (DOC 3541) with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses: Stephen C. Peters, Esq. [email protected]

and I hereby certify that I have mailed or served the document or paper to the following nonCM/ECF participants in the manner indicated: None

s/ Debbie Azua-Dillehay DEBBIE AZUA-DILLEHAY Legal Assistant Assistant United States Attorney United States Attorney's Office 1225 Seventeenth Street, Suite 700 Denver, Colorado 80202 Telephone: (303) 454-0100 FAX: (303) 454-0409 E-mail: [email protected]

3