Free Motion to Extend Time - District Court of Arizona - Arizona

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UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA
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LESLIE CHARLES CO$EN' 5 MOTION FOR MORE TIME TO FILE OBJECTIONS
Movant—Pet1tioner. } TO REPORT & RECOMMENDATION (DOC. #274)
COMES NOW the Movant-Petitioner, L. C. Cohen, pro se (Movant),
pursuant the Fifth and Sixth Amendments to the U.S. Constitution, the
Federal Rules of Civil Procedure (FRCVP) 6(b), Governing §2255 Proceed-
ings, and 28 U.S.C.A. §2255, with a Motion for More Time to File [His]
Objections to Report & Recommendation (Doc. #274) (R&R).
The Movant has commenced preparing his Objections for filing but
needs additional time to complete it. The R&R is very complicated and
lengthy (26 pages) requiring considerable cross—referencing and research.
Because of the Magistrate Judge's (MJ) use of transcript references (see
footnotes in R&R) not used by either parties in their prior pleadings,
the Movant needs to review those transcripts but does not have easy,
immediate access to them. His transcripts are in BOP locked storage
with his other legal files and obtaining them is at BOP convenience. As
a result of extensive week long (re)training sessions currently being
conducted at FCI Elkton there is a staff shortage of available BOP
personnel required to accompany Movant when he enters the BOP storage
area to select his legal materials.
Additionally, Movant's increased and spreading arthritis in both
his shoulders, arms and fingers - exasperated by the freezing, cold,
snow dampness of Ohio — has made preparing his legal pleadings
Case 2:01-cr-OOO99-JAT Documen`fE8O Filed O2/16/2006 Page1 0f2

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increasingly painful and slowed his ability to proceed quickly and
compete for one of the 10 typewriters available for some 2,000 inmates
to use. His hands are too crippled to write out the Objections legibly.
WHEREFORE, the Movant moves this Honorable Court for an Order
granting a further enlargement of time to prepare and file his
Objections to the MJ's Report & Recommendation (Doc. #274), and such
other relief as this Honorable Court deems law and justice require
as proper.
RESPECTFULLY SUBMITTED February 15, 2006. +””U`
L - C . COHEN 1
Movant—Petitioner pro se,
FCI Elkton
j Lisbon, OH
1 44432-0010
` CERTIFICATE OF FILING AND SERVICE
I HEREBY CERTIFY pursuant 28 U.S.C.A. §l746, an original and true
and correct copies of the foregoing Motion for More Time to File Object-
ions to Report & Recommendation (Doc. #274) were filed with this Court's
Clerk and served on the Respondent by prepaid first class mail in sealed
envelopes addressed to: Clerk, USDCAZ, 401 W. Washington St., SPC-1,
Phoenix, AZ 85003-2118: and AUSA J.L. Ireland, 40 N. Central Ave., #1200
Phoenix, AZ 85004-4408; by placing them in the internal mailing system
of FCI Elkton, Elkton, OH 444415-0089, on February 15, 2006, pursuant to
Houston v. Lack, 487 U.S. 266, 270 (1988).
L . C . COHEN:
Movant-Petitioner pro se,
FCI Elkton, P.O. Box 10,
Lisbon, OH 44432-0010
-2- _
Case 2:01 -cr-00099-JAT Document 280 Fnled O2/16/2006 Page 2 of 2

Case 2:01-cr-00099-JAT

Document 280

Filed 02/16/2006

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Case 2:01-cr-00099-JAT

Document 280

Filed 02/16/2006

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