Free Motion for Miscellaneous Relief - District Court of Colorado - Colorado

Case 1:00-cr-00531-WYD

Document 1938

Filed 09/29/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Criminal Case No. 00-cr-00531-WYD-01 UNITED STATES OF AMERICA, Plaintiff, v. 1. WILLIAM CONCEPCION SABLAN, Defendant.

GOVERNMENT'S UNOPPOSED MOTION FOR AMENDMENT OF SCHEDULING ORDER REGARDING SUBMISSION OF TRIAL EXHIBIT LIST

The United States of America, by Troy A. Eid, United States Attorney for the District of Colorado, and through Brenda K. Taylor and Philip A. Brimmer, Assistant U.S. Attorneys, respectfully requests that the Court amend its scheduling order of June 7, 2005 with regard to the date of submission of guilt phase trial exhibit lists. The reasons for this request are as follows: 1. The Court, in its Order of June 7, 2005, Docket number 1450, directed the parties to file their non-expert witness lists and their exhibit lists by October 13, 2006, approximately three months prior to trial. 2. Government counsel has conferred with Patrick Burke, counsel for William Sablan, and the parties agree that the October 13, 2006 deadline is premature for the filing

Case 1:00-cr-00531-WYD

Document 1938

Filed 09/29/2006

Page 2 of 4

of exhibit lists. 3. Based on the severance of the defendants and the filing of William Sablan's Rule 12.2 notice, the posture of this case has changed considerably since the time of the Court's original scheduling order. Both parties are working diligently to prepare for upcoming hearings regarding the penalty phase and other issues in addition to preparing for trial. 4. The parties will be filing their non-expert witness lists on October 13, 2006. The government is making every effort to compile a realistic list of witnesses and anticipates a shorter list than was discussed at the September 20, 2006 status hearing. 5. In order to allow the parties to compile realistic and complete exhibit lists as well, the government recommends, and defense counsel concurs, that the government's deadline for submission of a guilt phase trial exhibit list be December 15, 2006 and the defense deadline be December 22, 2006. WHEREFORE, the government, with the concurrence of defense counsel, respectfully requests that the Court amend its Order of June 7, 2005, to reflect that the government shall file its guilt phase trial exhibit list by December 15, 2006 and defendant William Sablan shall file his guilt phase trial exhibit list by December 22, 2006.

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Case 1:00-cr-00531-WYD

Document 1938

Filed 09/29/2006

Page 3 of 4

Respectfully submitted this 29 th day of September, 2006, TROY A. EID United States Attorney BY: s/ Brenda K. Taylor BRENDA K. TAYLOR Assistant U.S. Attorney U.S. Attorney's Office 1225 17th Street, Suite 700 Denver, Colorado 80202 Telephone (303)454-0100 FAX: (303) 454-0406 E-mail address: [email protected] Attorney for Government BY: s/ Philip A. Brimmer PHILIP A. BRIMMER Assistant U.S. Attorney U.S. Attorney's Office 1225 17th Street, Suite 700 Denver, Colorado 80202 Telephone (303)454-0100 FAX: (303) 454-0406 E-mail address: [email protected] Attorney for Government

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Case 1:00-cr-00531-WYD

Document 1938

Filed 09/29/2006

Page 4 of 4

CERTIFICATE OF SERVICE I hereby certify that on this 29th day of September, 2006, I electronically filed the foregoing GOVERNMENT'S UNOPPOSED MOTION FOR AMENDMENT OF SCHEDULING ORDER REGARDING SUBMISSION OF TRIAL EXHIBIT LIST with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses: Attorneys for William Sablan Patrick J. Burke [email protected] Nathan Dale Chambers [email protected] [email protected] Susan Lynn Foreman [email protected] Dean Steven Neuwirth [email protected] s/ Dorothy Burwell DOROTHY BURWELL Legal Assistant U.S. Attorney's Office 1225 17th Street, Suite 700 Denver, CO 80202 Phone (303) 454-0100 Fax (303) 454-0400 E-mail address [email protected] Attorneys for Rudy Sablan Forrest W. Lewis [email protected] Donald R. Knight [email protected]

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