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

Case 1:00-cr-00531-WYD

Document 1899

Filed 09/07/2006

Page 1 of 3

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. WILLIAM SABLAN'S MOTION FOR AN EXTENSION OF TIME TO FILE HIS RESPONSE TO THE GOVERNMENT'S AMENDED PROFFER OF PENALTY PHASE EVIDENCE

Defendant William Concepcion Sablan ("William"), by and through undersigned court-appointed counsel, moves for an extension of time to file his Response to the Government's Amended Proffer of Penalty Phase Evidence (Doc.#1884) to and including Tuesday, September 12, 2006.
1. On July 24, 2006, the government filed its Proffer Regarding Future Dangerousness (Doc.#1843). 2. On August 7, 2006 William Sablan's counsel filed their Response to the Government's July 24, 2006 Proffer Regarding Future Dangerousness (Doc.#1861). 3. Also, on August 7. 2006, William Sablan's counsel filed their Objections to the Government's July 24, 2006 Proffer based on its Incompleteness (Doc.#1862).

1

Case 1:00-cr-00531-WYD

Document 1899

Filed 09/07/2006

Page 2 of 3

4. On August 25, 2006, William Sablan's counsel filed their First (Doc.#1882) and Second (Doc.#1883) Supplemental Responses to the Government's July 24, 2006 Proffer Regarding Future Dangerousness. 5. On August 28, 2006, the government filed its Amended Proffer of Penalty Phase Evidence in Support of Non-Statutory Aggravating Factor of Future Dangerousness of William Sablan (Doc.#1884). The defense's Response to the Government's Amended Proffer is due September 8, 2006. 6. William Sablan's lawyers have been working diligently on their Response to the Government's Amended Proffer. However, defense counsel will need two (2) additional business days to finalize the Response to the Government's Amended Proffer. 7. The hearing on this matter is scheduled to commence on November 6, 2006, so the extension of two (2) business days will not disrupt the Court's schedule, nor prejudice the government in any way. WHEREFORE, the undersigned moves for an extension of time to and including Tuesday, September 12, 2006 in which to file its Response to the Government's Amended Proffer of Penalty Phase Evidence. Dated: September 7, 2006 Respectfully submitted,

/s/ Patrick J. Burke
Patrick J. Burke Patrick J. Burke, P.C. 1660 Wynkoop Street, Ste 810 Denver, CO 80202 (303) 825-3050 Nathan Chambers

2

Case 1:00-cr-00531-WYD

Document 1899

Filed 09/07/2006

Page 3 of 3

Chambers, Dansky & Mulvahill 1601 Blake Street, #300 Denver, CO 80202 (303) 825-2222 Susan L. Foreman 1660 Wynkoop Street, Ste 810 Denver, Colorado 80202 (303) 825-3050 CERTIFICATE OF SERVICE
th I hereby certify that on this 7 day of September, 2006 a true and correct copy of the above, WILLIAM SABLAN'S MOTION FOR AN EXTENSION OF TIME TO FILE HIS RESPONSE TO THE GOVERNMENT'S AMENDED PROFFER OF PENALTY PHASE EVIDENCE, was filed with the

Clerk of the Court using the CM/ECF system and was served via electronic mail to the following: Brenda Taylor ([email protected]) Phil Brimmer ([email protected]) Assistant U.S. Attorneys 1225 17th Street, Suite 700 Denver, Colorado 80202 /s/Jennifer J. Feldman

3