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

Attorney for Defendant

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA

) ) Plaintiff, ) ) vs. ) ) ANDREW TAYLOR, ) ) Defendant. ) __________________________________________)

UNITED STATES OF AMERICA,

NO: CR04-0809-PHX-NVW

MOTION TO EXTEND TIME FOR SELF SURRENDER

Defendant, Andrew Taylor, by and through counsel undersigned, hereby respectfully requests that this Court expend the time for him to self surrender to not earlier than 10 A.M., January 31, 2006, the time set for the restitution hearing in this matter. Defendant is currently scheduled to surrender at noon on January 30, 2006. Defendant has also filed a Motion for Release Conditions on Appeal and it is anticipated that the court can hear that matter during the restitution hearing. Defendant's counsel has discussed this matter with AUSA John Lopez who has no objection to the court allowing Mr. Taylor to remain free until the restitution hearing. He has not taken a position as yet concerning release conditions on appeal.

Case 2:04-cr-00809-NVW

Document 125

Filed 01/27/2006

Page 1 of 2

Based on the forgoing defendant respectfully requests that the court modify the self surrender order from January 30, 2006 to a time to be set by the court not earlier than January 31, 2006. RESPECTFULLY SUBMTTED this day of January, 2006.

Cameron A. Morgan Attorney for Defendant

COPY of the foregoing delivered this ____ day of January, 2006, to: Honorable N. V. Wake U.S. District Court 401 W. Washington Street Phoenix, Arizona 85003 John Lopez John Tuchi Assistant United States Attorney 40 N. Central Avenue, Ste. 1200 Phoenix, Arizona 85004

BY: __________________

2 Case 2:04-cr-00809-NVW Document 125 Filed 01/27/2006 Page 2 of 2