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

1 JON M. SANDS Federal Public Defender 2 District of Arizona Adams, Suite 3 850 West Arizona 85007201 Phoenix, 4 Telephone: (602) 382-2737 5 CRAIG ORENT, #015512 [email protected] 6 Asst. Federal Public Defender Attorney for Defendant 7 IN THE UNITED STATES DISTRICT COURT 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Underlying counsel was appointed to represent Mr. Beck on Thursday, April 17, 2008. At that same time, the Court ordered that Mr. Beck - and thus his counsel - provide the government certain items by April 21, 2008, at 12 p.m. These items were to include Mr. Beck's 2006 and 2007 tax returns, "and other documents v. Glen Beck, (Unopposed) Defendant. United States of America, Plaintiff, DISTRICT OF ARIZONA No. CR 03-00890-PHX-JAT DEFENDANT'S REQUEST FOR AN EXTENSION OF THE APRIL 21, 2008, 12 PM, DISCLOSURE DEADLINE

22 or exhibits supporting defendant's financial presentation to the Government." Mr. Beck, through counsel, has provided the government his 2006 tax 23 24 returns, and, per the government's request, documents reflecting a requested 25 extension of the filing of the 2007 tax returns. However, given the state of 26 underlying counsel's preparedness and knowledge of the case, he is unable at this 27 28

Case 2:03-cr-00890-JAT

Document 91

Filed 04/21/2008

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1 time to comply with the remaining part of the Court's order. 1 Counsel contacted both 2 Assistant United States Attorneys, Darcy Cerow and Howard Sukenic, and neither 3 opposes this request. 4 5 6 7 8 9 s/Craig Orent CRAIG ORENT Asst. Federal Public Defender Respectfully submitted: April 21, 2008. JON M. SANDS Federal Public Defender

10 I hereby certify that on April 21, 2008, I electronically transmitted the attached document to the Clerk's Office using the ECF System for filing and transmittal to the 11 following ECF registrants: 12 Darcy Cerow & Howard Sukenic 13 Assistant United States Attorneys 14 Copy mailed to: 15 Glen Beck 16 Defendant 17 18 19 20 21 22 23 24 25 26 27 28 Counsel references and incorporates by reference the motion to continue the disposition and restitution hearing, filed on Friday, April 18, 2007, Doc. #90.
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s/ Susan L. West

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Case 2:03-cr-00890-JAT

Document 91

Filed 04/21/2008

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