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

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Tonya J. McMath State Bar #012281 111 West Monroe, Suite 1650 Phoenix, Arizona 85003 (602) 254-5544 Attorney for Defendant UNITED STATES DISTRICT COURT

5 DISTRICT OF ARIZONA 6 7 8 9 10 11 Defendant, Paul K. Bryan, through undersigned counsel, respectfully moves this Court to 12 extend the date for his voluntary self-surrender to the Bureau of Prisons for service of his sentence 13 for an additional thirty (30) days until the time of designation or no later than 12:00 p.m. on 14 August 4, 2006. The reason for this motion is that, at the time of Mr. Bryan's sentencing on April 15 11, 2006, it was specifically contemplated that Mr. Bryan be classified to an institution prior to 16 his self-surrender date and that a motion to extend Mr. Bryan's self-surrender date may be 17 forthcoming if designation was unlikely to occur by the original self-surrender deadline of June 18 5, 2006. (See Partial Transcript of Sentencing Proceedings conducted April 11, 2006, pp. 69-72, 19 attached as Exhibit "A" to Mr. Bryan's Request to Extend Date for Voluntary Self-Surrender filed 20 May 15, 2006 ("First Request to Extend")). For this reason, this Court previously extended Mr. 21 Bryan's self-surrender deadline for a period of thirty (30) days. 22 As of the date of this filing, Mr. Bryan still has not been designated to a facility by the 23 Department of Corrections. Given this information, information presented in Mr. Bryan's First 24 Request to Extend, and the fact that undersigned counsel is being married out of state and will be 25 out of the office for that purpose from June 22, 2006 until July 10, 2006, counsel has elected to 26 file the instant motion at the present time in an abudance of caution. Obviously, should Mr. 27 Bryan's designation be accomplished prior to the present self-surrender deadline of July 5, 2006, 28 ) ) Plaintiff, ) v. ) ) Paul K. Bryan, ) ) Defendant. ) ____________________________________) United States of America, No. CR 03-1269-PHX-NVW REQUEST TO EXTEND DATE FOR VOLUNTARY SELF-SURRENDER (Second Request)

Case 2:03-cr-01269-NVW

Document 280

Filed 06/19/2006

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that deadline effectively will have remained unchanged. Undersigned counsel has contacted Assistant United States Attorney Michelle R. Hamilton who has indicated that the government does not oppose the requested extension. Respectfully submitted this 19th day of June, 2006. By _/s/ Tonya J. McMath Tonya J. McMath Attorney for Defendant Copy of the foregoing filed/delivered via the CM/ECF system this 19th day of June, 2006 and delivered to the following ECF registered recipients: Michelle R. Hamilton 40 North Central, Ste. 1200 Phoenix, AZ 85004 Paul V. Rood 40 North Central, Ste. 1200 Phoenix, AZ 85004 By /s/ T. McMath

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Case 2:03-cr-01269-NVW

Document 280

Filed 06/19/2006

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