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

Case 1:04-cr-00103-REB-MEH

Document 1273

Filed 06/14/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Criminal Case No. 04-cr-00103-REB-06 UNITED STATES OF AMERICA Plaintiff, v. 6. MICHAEL SMITH, Defendant. _____________________________________________________________________ GOVERNMENT'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO RESPOND _____________________________________________________________________ The United States, by Wyatt Angelo and Matthew T. Kirsch, the undersigned Assistant United States Attorneys, hereby moves for a brief extension of time to respond to defendant Smith's MOTION FOR A JUDGMENT OF ACQUITTAL [#1257]. In support, the government says: 1. The motion was filed on June 5, 2007. On June 6, 2007, the Court issued a Minute Order [# 1258] directing the government to respond by June 18, 2007. 2. Given the extended nature of the trial proceedings, the government is requesting a brief extension to review its notes, trial exhibits, and other relevant information and to better draft a cogent response to defendant Smith's motion. 3. The undersigned has contacted counsel for defendant Smith and has been told that defendant Smith does not oppose the requested extension. THEREFORE, the government requests that the Court grant an extension of time to respond to defendant Smith's MOTION FOR A JUDGMENT OF ACQUITTAL

Case 1:04-cr-00103-REB-MEH

Document 1273

Filed 06/14/2007

Page 2 of 3

[#1257] until June 22, 2007. Respectfully submitted this 14th day of June, 2007, TROY A. EID United States Attorney

s/ Matthew T. Kirsch WYATT ANGELO MATTHEW T. KIRSCH Assistant U.S. Attorneys 1225 17th Street, Suite 700 Denver, CO 80202 Telephone: (303) 454-0100 Facsimile: (303) 454-0402 Email: [email protected] [email protected]

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Case 1:04-cr-00103-REB-MEH

Document 1273

Filed 06/14/2007

Page 3 of 3

CERTIFICATE OF SERVICE I certify that on the 14th day of June, 2007, I electronically filed the foregoing with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses: Peter Bornstein, Esq. [email protected] Thomas Hammond, Esq. [email protected] Declan J. O'Donnell, Esq. [email protected] Richard N. Stuckey, Esq. [email protected] Thomas Goodreid, Esq. [email protected] Ronald Gainor, Esq. [email protected]

s/ Matthew T. Kirsch MATTHEW T. KIRSCH Assistant U.S. Attorney 1225 17th Street, Suite 700 Denver, CO 80202 Telephone: (303) 454-0100 Facsimile: (303) 454-0402 Email: [email protected]

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