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

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Brian F. Russo (018594) 111 West Monroe Street Suite 1212 Phoenix, Arizona 85003 (602) 340-1133 telephone (602) 258-9179 facsimile e-mail: [email protected] Attorney for Defendant Robert Johnston Jr. IN THE UNITED STATES DISTRICT COURT IN AND FOR THE DISTRICT OF ARIZONA UNITED STATES OF AMERICA, Plaintiff, vs. ROBERT J. JOHNSTON, JR. (1), Defendant. ) ) ) ) ) ) ) ) ) ) Case No. CR 03-1167 PHX-DGC MOTION TO EXTEND TIME TO FILE REPLY TO GOVERNMENT'S RESPONSE (Docket # 1047)

COMES NOW the defendant, Robert J. Johnston, Jr., by and through Counsel, Brian F. Russo, and hereby moves this Honorable Court for an order extending

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time to file defendant's reply to Government's response (#1047) of defendant's Motion to Suppress (#977) for a period of three days to January 30, 2006. Defense Counsel has approximately five replies he is currently working on in this matter. Counsel respectfully requests an extension of three days to file

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defendant's reply to Government's response (#1047) in order to properly prepare and complete defendant's reply.

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Case 2:03-cr-01167-DGC

Document 1106

Filed 01/24/2006

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Excludable delay under 18 U.S.C. § 3161 (h)(8)(A) may occur as a result of this motion or from an order based thereon.

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RESPECTFULLY SUBMITTED this 24th day of January, 2006.

/s/Brian F. Russo Brian F. Russo Attorney for Defendant

COPY of the foregoing electronically mailed this 24th day of January, 2006, to: Tim Duax Keith Vercauteran Asst. U.S. Attorneys All Defense Counsel /s/

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Case 2:03-cr-01167-DGC

Document 1106

Filed 01/24/2006

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