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

Case 1:03-cr-00128-WYD

Document 233

Filed 05/04/2007

Page 1 of 2

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Criminal Case Number: 03-cr-00128-WYD UNITED STATES OF AMERICA, Plaintiff, v. DANA WEST Defendant.

MOTION FOR EXTENSION OF TIME TO FILE MOTION TO DISMISS AND TO CONTINUE MOTIONS HEARING AS TO ALL ISSUES EXCEPT THE DEFENDANT'S RELEASE

Defendant, Dana West a.k.a "Abraham", by and through the law firm of Springer and Steinberg, P.C., hereby moves the Court for an Order granting an extension of time to file motions in this matter. AS GROUNDS THEREFORE, Defendant states as follows: 1. The law firm of Springer and Steinberg was retained by Abraham on April 25, 2007. Undersigned counsel has begun reviewing the facts of this case and is currently preparing a Motion to Dismiss. However, undersigned counsel needs an additional ten (10) days to prepare and file this motion. A Motions Hearing is currently set for May 8, 2007 at 2:00 pm. However, Mr. Steinberg will be in trial on May 8, 2007 and therefore cannot be present. The Defendant therefore requests that only the issue of the Defendant's release be addressed at the Motions Hearing on May 8, 2007. The Defendant further requests that all other issues be addressed at a future motions hearing.

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WHEREFORE, Defendant respectfully requests that this motion be granted. DATED this 4th day of May, 2007.

Case 1:03-cr-00128-WYD

Document 233

Filed 05/04/2007

Page 2 of 2

Respectfully submitted, s/Harvey A. Steinberg Harvey A. Steinberg Attorneys for Dana West 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 May 4, 2007, I electronically filed the foregoing MOTION FOR EXTENSION OF TIME TO FILE MOTION TO DISMISS AND TO CONTINUE MOTIONS HEARING AS TO ALL ISSUES EXCEPT THE DEFENDANT'S RELEASE with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses:

Jim Hearty [email protected]

s/Brenda Rodriguez For Harvey A. Steinberg Attorneys for Dana West 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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