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

Case 1:01-cr-00437-LTB

Document 138

Filed 08/27/2008

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Criminal Case No. 01-cr-00437-LTB UNITED STATES OF AMERICA, Plaintiff, v. 1. BERT SANDERS, Defendant.

UNOPPOSED MOTION FOR EXTENSION OF TIME

COMES NOW the Defendant, Bert Sanders, by and through his attorney, Charles W. Elliott, and hereby moves this Honorable Court for a two week extension of time to file the response to the Court's Order of August 7, 2008, as grounds therefore, states as follows: 1. That this Honorable Court Ordered that Counsel for the Defendant and the

Government file a response indicating whether or not the Defendant is eligible for the sentence reduction pursuant to 18 U.S.C. § 3582(c)(2) on or before August 27, 2008. 2. That counsel for the Defendant has conferred with counsel for the Government,

James Boma, who does not oppose an extension of time. 3. 4. That Mr. Boma has just received the file in the instant case from storage. That a two week extension of time is necessary to properly submit the appropriate

response pleadings. WHEREFORE, the Defendant prays this Honorable Court grant his Unopposed Motion for Extension of Time. Dated this 25th day of August, 2008.

Case 1:01-cr-00437-LTB

Document 138

Filed 08/27/2008

Page 2 of 3

Respectfully submitted, s/ Charles W. Elliott __________________________________________ The Law Office of Charles W. Elliott 1801 Broadway Ste 1100 Denver, CO 80202 Telephone: (303) 623-2013 Facsimile: (303) 292-0522 E-mail: [email protected] Attorney for Defendant Bert Sanders

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Case 1:01-cr-00437-LTB

Document 138

Filed 08/27/2008

Page 3 of 3

CERTIFICATE OF SERVICE I do hereby certify that on the 25th day of August 2008, I electronically filed the foregoing UNOPPOSED MOTION FOR EXTENSION OF TIME with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses: James Boma [email protected]

s/ Holly Muncy ____________________________________ Holly Muncy The Law Office of Charles W. Elliott 1801 Broadway Ste 1100 Denver, CO 80202 Telephone: (303) 623-2013 Facsimile: (303) 292-0522 E-mail: [email protected]

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