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

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PAUL K. CHARLTON United States Attorney District of Arizona MICHAEL A. LEE Special Assistant U.S. Attorney Two Renaissance Square 40 North Central Avenue, Suite 1200 Phoenix, Arizona 85004-4408 Arizona State Bar No. 018065 Telephone (602) 514-7500 [email protected]

UNITED STATES DISTRICT COURT
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DISTRICT OF ARIZONA
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United States of America, Plaintiff, v. Gregorio Miranda-Martinez, Defendant.

CR-04-0345-PHX-EHC CV-06-920-PHX-EHC (BPV) MOTION FOR ENLARGEMENT OF TIME

The United States, by and through its attorneys undersigned, respectfully requests this Court enter an order enlarging the time for the government to respond to defendant Gregorio Miranda-Martinez's Motion Under 28 U.S.C. § 2255 to Vacate, Set Aside, or Correct Sentence By a Person in Federal Custody, until August 15, 2006. The government's response is presently due on June 12, 2006. The government is requesting this time in order to continue its research in preparing its response and coordinate the response with defendant's trial counsel who the defendant has claimed to be ineffective. In addition, the government ordered the relevant

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Case 2:04-cr-00345-EHC

Document 29

Filed 06/15/2006

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transcripts (change of plea and sentencing) on May 18, 2006, and have not received them as of today's date. Respectfully submitted this 5th day of June, 2006. PAUL K. CHARLTON United States Attorney District of Arizona S/ Michael A. Lee

7 8 9 10 11 12 13 14 15 16 17 CERTIFICATE OF SERVICE

MICHAEL A. LEE Special Assistant U.S. Attorney

I hereby certify that on June 5, 2006, I electronically transmitted the attached document to the Clerk's Office using the CM/ECF system for filing. I hereby certify that on August 23, 2005, I served the attached document by mail on the following who are not registered participants of the CM/ECF system: Gregorio Miranda-Martinez S/ Michael A. Lee

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Case 2:04-cr-00345-EHC

Document 29

Filed 06/15/2006

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