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

1 JON M. SANDS Federal Public Defender 2 District of Arizona 850 W. Adams, Suite 201 3 Phoenix, Arizona 85007 4 Telephone: (602) 382-2749 5 GERALD A. WILLIAMS, #013115 Asst. Federal Public Defender 6 Attorney for Defendant [email protected] 7 IN THE UNITED STATES DISTRICT COURT 8 DISTRICT OF ARIZONA 9 10 11 12 13 14 15 16 17 The defendant, by and through undersigned counsel, respectfully 18 requests that the date for Ms. Flores to self-surrender be extended an additional ten 19 (10) days. Additional time is needed to allow Ms. Flores to secure placement for the 20 defendant's minor son, A.F. A.F. is autistic and has serious congenitive disabilities. 21 Ms. Flores was inadvertently informed that her self-surrender deadline had been reset 22 to November 30 and it was not until November 20 at 11:00 a.m. that Ms. Flores 23 learned that November 20 is the correct date as ordered by the Court. 24 Since the last extension, Ms. Flores has been interviewing caretakers for 25 26 her son and has located a caretaker. However, her case worker has not yet met and 27 approved the new caretaker. Ms. Flores also has to take care of some administrative 28 matters with a bank to allow the caretaker to receive her son's Social Security payments through direct deposit. vs. Linda Flores, Defendant. United States of America, Plaintiff, No. CR-02-1153-PHX-ROS EMERGENCY MOTION TO EXTEND TIME TO SELF-SURRENDER (Second Request) (Expedited Ruling Requested)

Case 2:02-cr-01153-ROS

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Filed 11/20/2006

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Assistant U.S. Attorney Darcy Cerow could not be reached at the time

2 of the filing of this motion. Her position is unknown. 3 It is expected that excludable delay under Title 18 U.S.C. § 4 3161(h)(1)(F) may occur as a result of this motion or from an order based thereon. 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
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Respectfully submitted: November 20, 2006. JON M. SANDS Federal Public Defender

s/Deborah Euler-Ajayi for Gerald A. Williams DEBORAH EULER-AJAYI for GERALD A. WILLIAMS Asst. Federal Public Defender

Case 2:02-cr-01153-ROS

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1 Copy of the foregoing transmitted by ECF for filing this 20th day 2 of November, 2006, to: 3 CLERK'S OFFICE 4 United States District Court Sandra Day O'Connor Courthouse 5 401 W. Washington Phoenix, Arizona 85003 6 DARCY CEROW 7 Assistant U.S. Attorney United States Attorney's Office 8 Two Renaissance Square 40 N. Central Avenue, Suite 1200 9 Phoenix, Arizona 85004-4408 10 Copy mailed to: 11 United States Marshal's Office 12 Sandra Day O'Connor Courthouse 401 W. Washington 13 Phoenix, Arizona 85003 14 ADELINA BUSTAMANTE United States Probation 15 Sandra Day O'Connor Courthouse 401 W. Washington, Suite 160 16 Phoenix, Arizona 85003 17 LINDA FLORES 18 Defendant 19 20 21 22 23 24 25 26 27 28
s/T.Gutierrez
\ExtendSelfSurrenderMTN2

Case 2:02-cr-01153-ROS

Document 26

Filed 11/20/2006

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