Free Motion for Extension of Time to File - District Court of Colorado - Colorado

Case 1:00-cr-00531-WYD

Document 2421

Filed 03/22/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Criminal Action No. 1:00-cr-000531-WYD UNITED STATES OF AMERICA, Plaintiff, v. WILLIAM CONCEPCION SABLAN, Defendant.
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William Sablan's Motion for Extension of Time to File a Motion for Judgment of Acquittal ________________________________________________________________________ Defendant William Sablan ("William"), through undersigned court-appointed counsel, respectfully moves for an extension of time to file a motion for judgment of acquittal under Fed. R. Crim. P. 29. As grounds, counsel state: 1. On March 15, 2007, the jury returned a verdict, finding William Sablan guilty of first degree murder. 2. The jury, however, has not yet been discharged because this is a capital case and it is continuing into a sentencing hearing before the same jury. 3. Although Rule 29(c)(1) appears to allow the defendant to file a motion for judgment of acquittal either 7 days after the verdict or 7 days after the jury has been discharged, in an abundance of caution, Mr. Sablan now moves for an extension of time
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Case 1:00-cr-00531-WYD

Document 2421

Filed 03/22/2007

Page 2 of 3

in which to file a motion for a judgment of acquittal. WHEREFORE, William Sablan respectfully requests that he have up to and including seven (7) days after the jury has returned its sentencing verdict and is discharged from further proceedings in this case in which to file a motion for a judgment of acquittal. Dated: March 22, 2007 Respectfully submitted, Patrick J. Burke Patrick J. Burke P.C. 1660 Wynkoop Street, Suite 810 Denver, CO 80202 303-825-3050 By: /s/ Susan L. Foreman Susan L. Foreman 1660 Wynkoop Street, Suite 810 Denver, CO 80202 303-825-3050 Counsel for William Sablan Nathan Chambers Chambers, Dansky & Mulvahill 1601Blake Street, Suite 300 Denver, CO 80202 303-825-2222

CERTIFICATE OF SERVICE
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Case 1:00-cr-00531-WYD

Document 2421

Filed 03/22/2007

Page 3 of 3

I hereby certify that on March 22, 2007, I electronically filed the foregoing William Sablan's Motion for Extension of Time to file a Motion for Judgment of Acquittal with the Clerk of the Court using the CM/EFC system which will send notification of such filing to the following e-mail addresses: [email protected] [email protected] By: /s/Susan L. Foreman

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