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 Bella Ben-Henry, Defendant. Defendant Bella Ben-Henry, through counsel, moves this Court to extend

16 her self-surrender deadline of January 5, 2007 for a period of 60 days. This extension 17 will allow the Bureau of Prisons (BOP) to designate the defendant. In mid18 December, undersigned counsel began inquiring with the U.S. Marshals Service 19 about Ms. Ben-Henry's designation. On December 28, 2006, undersigned counsel 20 spoke with Karen Craighead, the individual with the Bureau of Prisons who is in 21 charge of designations for the District of Arizona. Ms. Craighead advised that the 22 BOP has not yet received Ms. Ben-Henry's file. Accordingly, Ms. Ben-Henry has not 23 been designated. Ms. Craighead stated that Ms. Ben-Henry would likely be 24 designated within 60 days. This Court sentenced Ms. Ben-Henry to eight months in prison. The 25 26 Court also ordered Ms. Ben-Henry to self-surrender to the U.S. Marshal's Office in 27 Phoenix, or to her BOP designation, on or before January 5, 2007. On December 27, 28 2006, Ms. Ben-Henry provided to undersigned counsel a letter from her primary care

Case 2:04-cr-01018-JAT

Document 156

Filed 12/29/2006

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1 physician indicating that she requires ongoing medical care due to a painful condition 2 (psoriasis) on her hands and feet. The letter is attached hereto as Exhibit A. Because 3 of her medical condition, it would be better for Ms. Ben-Henry to report to her 4 designated placement, rather than having to spend an undetermined amount of time 5 in transit. 6 8 10 11 12 13 14 15 Therefore, Ms. Ben-Henry requests that this Court give her the Defense counsel has attempted to contact Assistant United States Respectfully submitted: December 29, 2006. JON M. SANDS Federal Public Defender s/Milagros A. Cisneros MILAGROS A. CISNEROS Assistant Federal Public Defender 7 opportunity to self-surrender once she has been designated. 9 Attorney Dan Drake concerning this motion, but Mr. Drake is out of the office.

I hereby certify that on December 29, 2006, I electronically transmitted the attached 16 document to the Clerk's Office using the ECF System for filing and transmittal to the following ECF registrants: 17 DAN DRAKE 18 Assistant U.S. Attorney Two Renaissance Square 19 40 N. Central, Suite 1200 Phoenix, Arizona 85004-4408 20 Copy mailed to 21 BELLA BEN-HENRY 22 Defendant 23 25 26 27 28 2 s/Milagros A. Cisneros 24 M. Cisneros

Case 2:04-cr-01018-JAT

Document 156

Filed 12/29/2006

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