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

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6 UNITED STATES DISTRICT COURT
7 DISTRICT OF ARIZONA
8 United States of America
9 CR—03-742-01-PHX-SRB
Plaintiff,
10 v. GOVERNMENT’S REQUEST FOR
EXTENSION OF TIME
11 Juan Sanchez-Hurtado
(Under Seal)
12 Defendant.
13 The United States of America, by and through its attomeys undersigned, hereby requests an
14 extension of time to respond to defendant’s Objections to the Court’s Imposition of
15 Probation! Supervised Release filed on June 4, 2007. This request is supported by the attached
16 Memorandum of Points and Authorities.
17 Excludable delay pursuant to Title 18 U.S.C. §3 161 will not occur as a result of this motion
18 or an order based thereon.
19 Respectfully submitted this 22“d day of June, 2007.
20 DANIEL G. KNAUSS
United States Attomey
21 D` trjict of Arizona ,
22 I M/MZ &4¢/MJ"
23 ARC A. CEROW
24 Assistant U.S. Attorney
25
26
27
28
Case 2:03—or—00742-SRB Document 21 Filed 06/22/2007 Page 1 of 2

1 MEMORANDUM OF POINTS AND AUTHORITIES
2 On June 12, 2007, undersigned counsel was informed by the Court that on June 4, 2007, the
3 defendant filed objections to the court’s imposition of probation/ supervised.Because undersigned
4 counsel had not received a copy of the motion, the court faxed a copy so that the government
5 could respond. Due to undersigned counsel’s absence from the office on emergency family
6 leave, no response was filed with the Court by June 18, 2007 as required by the Rules.
7 Undersigned counsel returned to the office on June 18, 2007 and reviewed defendant’s
8 motion. The defendant alleges, among other things, that he did not receive notice that one of
9 his conditions of supervised release was that he not re-enter the United States without permission
10 from the government. In order to determine whether or not the defendant received such notice,
11 undersigned counsel has ordered a transcript of defendant’s sentencing hearing. Therefore, the
12 government requests an extension of time of at least 35 days to respond to defendant’s motion.
13 This extension will allow sufficient time to have the sentencing transcript prepared by the court
14 reporter and reviewed by undersigned counsel. The defendant is currently in custody for illegally
15 re-entering the United States with a projected release date of December 30, 2008.
16 Excludable delay pursuant to Title 18 U.S.C. §3 161 will not occur as a result of this motion
17 or an order based thereon.
18 Respectfully submitted this 22"d day of June, 2007.
19 DANIEL G. KNAUSS
U. S. Attorney
20 Di Iict of Arizona
, #2 K
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ARCY A. CEROW
23 Assistant U.S. Attorney
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25 Sanchez Hurtado Juan
Re . No. 618-208
26 Cagfornia Citg Correctional Center
P.O. Box 259
California City, CA 93504
27
28 2
Case 2:03—cr—00742-SRB Document 21 Filed 06/22/2007 Page 2 of 2

Case 2:03-cr-00742-SRB

Document 21

Filed 06/22/2007

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Case 2:03-cr-00742-SRB

Document 21

Filed 06/22/2007

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