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 vs. Linda Flores, Defendant. The defendant, by and through undersigned counsel, respectfully United States of America, Plaintiff, No. CR-02-1153-PHX-ROS MOTION TO EXTEND TIME TO SELF-SURRENDER (First Request)

17 requests that the date for Ms. Flores to self-surrender be extended approximately 18 three (3) weeks. The reason for the request is that additional time is needed to allow 19 20 21 22 23 24 the family's Support Coordinator, Patricia Diaz of the Department of Economic Security, to find placement for the defendant's minor son, A.F. According to Ms. Diaz, A.F. is autistic and has serious congenitive disabilities. They are trying to minimize the trauma of having to relocate by keeping him in the same school. She believes the transition, temporarily losing his mother,

25 and changing school would be very traumatic to A.F. Ms. Flores believes an 26 additional three weeks would give her enough time to resolve the matter. 27 Assistant U.S. Attorney Darcy Cerow is out of the office. Assistant U.S. 28 Attorney Glenn McCormick is the duty attorney and stated he will abide by the Court's ruling.

Case 2:02-cr-01153-ROS

Document 24

Filed 10/26/2006

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It is expected that excludable delay under Title 18 U.S.C. §

2 3161(h)(1)(F) may occur as a result of this motion or from an order based thereon. 3 Respectfully submitted: October 26, 2006. 4 5 6 7 8 9 Copy of the foregoing transmitted th ECF for 10 by October, filing this 26 day of 2006, to: 11 CLERK'S OFFICE 12 United States District Court Sandra Day O'Connor Courthouse 13 401 W. Washington Phoenix, Arizona 85003 14 DARCY CEROW 15 Assistant U.S. Attorney United States Attorney's Office 16 Two Renaissance Square 17 40 N. Central Avenue, Suite 1200 Phoenix, Arizona 85004-4408 18 Copy mailed to: 19 United States Marshal's Office 20 Sandra Day O'Connor Courthouse 401 W. Washington 21 Phoenix, Arizona 85003 22 LINDA FLORES 23 Defendant 24 25 26 27 28
s/T.Gutierrez
\ExtendSelfSurrenderMTN

JON M. SANDS Federal Public Defender

s/Gerald A. Williams GERALD A. WILLIAMS Asst. Federal Public Defender

Case 2:02-cr-01153-ROS

Document 24

Filed 10/26/2006

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