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

1 JON M. SANDS Federal Public Defender 2 District of Arizona 850 West Adams, Suite 201 3 Phoenix, Arizona 85007-2730 Telephone: 602-382-2727 4 MILAGROS A. CISNEROS 5 State Bar # 020410 Asst. Federal Public Defender 6 [email protected] Attorney for Defendant 7 IN THE UNITED STATES DISTRICT COURT 8 FOR THE DISTRICT OF ARIZONA 9 10 United States of America, No. CR 04-1018-PHX-JAT Plaintiff, 11 MOTION TO EXTEND vs. SELF-SURRENDER DEADLINE 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Bella Ben-Henry, Defendant. (Second Request) (Unopposed)

Defendant Bella Ben-Henry, through undersigned counsel, moves this Court to extend her self-surrender deadline of March 1, 2007 for a period of three days, until March 4, 2007. Ms. Ben-Henry has advised undersigned counsel that her daughter who resides in Oklahoma will be arriving in Arizona on March 3, 2007 and it is her family's desire that this daughter accompany Ms. Ben-Henry to FCI-Phoenix for her self-surrender. In addition, Ms. Ben-Henry's family has arranged for a medicine man to conduct a traditional ceremony on her behalf on the evening of March 3, 2007. This is the only time available for such a ceremony. Accordingly, it is requested that Ms. Ben-Henry be allowed to self-surrender by the afternoon of March 4, 2007. ... ... ... ...

Case 2:04-cr-01018-JAT

Document 161

Filed 02/14/2007

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Undersigned counsel has contacted Assistant United States Attorney Dan

2 Drake concerning this motion, and Mr. Drake has no objection to the brief 3 continuance requested herein. 4 5 6 7 8 9 Respectfully submitted: February 14, 2007. JON M. SANDS Federal Public Defender s/Milagros A. Cisneros MILAGROS A. CISNEROS Assistant Federal Public Defender

I hereby certify that on February 14, 2007, I electronically transmitted the attached 10 document to the Clerk's Office using the ECF System for filing and transmittal to the following ECF registrants: 11 DAN DRAKE 12 Assistant U.S. Attorney Two Renaissance Square 13 40 N. Central, Suite 1200 Phoenix, Arizona 85004-4408 14 Copy mailed to 15 BELLA BEN-HENRY 16 Defendant 17 19 20 21 22 23 24 25 26 27 28 2 s/Milagros A. Cisneros 18 M. Cisneros

Case 2:04-cr-01018-JAT

Document 161

Filed 02/14/2007

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