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

Case 1:04-cr-00433-WDM

Document 482

Filed 03/01/2006

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UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Criminal Case Number 04-cr-00433-WDM UNITED STATES OF AMERICA, Plaintiff, v. JORGE LUIS CORONA, Defendant.

UNOPPOSED MOTION FOR EXTENSION OF TIME BY WHICH TO FILE PRETRIAL MOTIONS OR IN THE ALTERNATIVE TO FILE A NOTICE OF DISPOSITION

The Defendant, Jorge Luis Corona, by and through his attorney, Harvey A. Steinberg, of the law firm of Springer and Steinberg, P.C., hereby moves this Court for an Order granting an additional 10 days to file all pretrial motions. AS GROUNDS THEREFORE, the Defendant states as follows: 1. 2. In this matter, pretrial motions are due to be filed on or before March 1, 2006. This Court has been very patient with regards to the filing of motions, although it is

important to note undersigned counsel is substitute counsel. 3. Undersigned counsel has had numerous discussions in an attempt to resolve this

case. After discussions on February 28, 2006, and March 1, 2006, with both Gregory Rhodes and Gregory Holloway, it appears that a disposition will be reached. 4. The government has no objection to this motion being granted and it is anticipated

that within the next 10 days a notice of disposition will be filed.

Case 1:04-cr-00433-WDM

Document 482

Filed 03/01/2006

Page 2 of 3

WHEREFORE, the Defendant requests this Motion be granted. DATED THIS 1ST DAY OF MARCH, 2006. Respectfully submitted, s/Harvey A. Steinberg Attorney for Jorge Luis Corona Springer & Steinberg, P.C. 1600 Broadway, Suite 1200 Denver, CO 80202 (303)861-2800 Telephone (303)832-7116 Telecopier [email protected]

CERTIFICATE OF SERVICE I hereby certify that on March 1, 2006, I electronically filed the UNOPPOSED MOTION FOR EXTENSION OF TIME BY WHICH TO FILE PRETRIAL MOTIONS OR IN THE ALTERNATIVE TO FILE A NOTICE OF DISPOSITION with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses:

Wayne Campbell Email: [email protected] Mitchell Baker Email: [email protected] Richard James Bana Email: [email protected] Darren Randal Cantor Email: [email protected] Martha Horwits Eskesen Email: [email protected] Michael Paul Litman Email: [email protected]

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Case 1:04-cr-00433-WDM

Document 482

Filed 03/01/2006

Page 3 of 3

Robert S. McCormick Email: [email protected] Lisa Anne Polansky Email: [email protected] Daniel Joseph Sears Email: [email protected] Barrett Thomas Weisz Email: [email protected]

s/Jan Cooley For Harvey A. Steinberg Attorney for Jorge Luis Corona Springer & Steinberg, P.C. 1600 Broadway, Suite 1200 Denver, CO 80202 (303)861-2800 Telephone (303)832-7116 Telecopier [email protected]

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